How to Enforce Foreign Judgments in Turkey in 2026?

Understanding the enforcement of foreign judgments in Turkey is essential for both individuals and companies seeking to protect their legal rights, recover debts, or register personal status decisions such as divorce or custody judgments.

Because the globalizing world leads to the spread of commercial and individual relations to wide geographies and the expansion of the network of relations. So, when a company in Turkey does business with a European company, it can choose the competent court and law from outside of Turkey and the dispute can be resolved by foreign courts. To make such a decision legally valid and executable, a procedure called the recognition and enforcement of foreign judgments in Turkey must be completed before the competent Turkish courts. In this article, we will first examine the legal basis and conditions of recognition and enforcement of foreign court decisions, then touch on the procedure and then answer frequently asked questions.

Legal Basis for Recognition and Enforcement of Judgments in Turkey

Each sovereign state makes its own judgment. The natural consequence of this sovereignty is the direct implementation of the decisions of the courts of that state. For this reason, decisions made in a foreign country cannot be implemented unless they are recognized in the country of a sovereign state. Recognition and enforcement of foreign court decisions in Turkey are regulated in the Law on Private International Law and Procedural Law. The relevant law includes the procedures and principles for both the personal rights included in criminal decisions and the recognition and enforcement of civil trial decisions.

How to Enforce a Foreign Judgment in Turkey

In order to enforce a foreign judgment in Turkey, the decision must first be officially recognized and approved by a Turkish court. According to Article 50 of the Turkish Private International Law and Procedural Law (Law No. 5718), the execution of judgments issued by foreign courts and finalized under the laws of that country is only possible after obtaining an enforcement decision (tenfiz kararı) from the competent Turkish court.

In practice, this means that the foreign judgment must be rendered by a legitimate judicial authority, it must be final and binding according to the foreign country’s legal system, and it must be granted enforcement by the relevant Turkish court. Only when these general requirements are satisfied can a foreign court decision be recognized and enforced in Turkey. The following sections explain these general and special conditions in detail.

General conditions

1) The institution making the decision must be a court

The first requirement for the recognition and enforcement of foreign judgments in Turkey is that the decision must be issued by a competent court. A court, under the laws of the state where the judgment originates, is a public judicial authority empowered to render legally binding decisions. Therefore, rulings made by private or non-judicial bodies cannot be recognized or enforced in Turkey under the provisions of the Turkish Private International Law.

2) The decision must be final

Another essential condition for the recognition and enforcement of foreign court decisions in Turkey is that the judgment must be final and binding. A ruling that has not yet become final in the country where it was issued cannot be recognized or enforced in Turkey, and no legal action can be based on it. The finality of a foreign judgment is determined according to the laws of the country in which it was rendered. During the evaluation process, the Turkish court will review whether the decision has attained final status under that foreign legal system; if it has, the court may then issue a ruling for its recognition and enforcement in Turkey.

“Since the final judgment will have its effect and result from the moment the foreign court decision becomes final in that country, the parties will be divorced on that date. In this respect, since the outcome of the recognition and enforcement case will affect this case, it was necessary to wait for the recognition and enforcement decision to be finalized…Recognition and Enforcement of Foreign Court Decisions in Turkey Supreme Court Decision – 2nd CC., E. 2019/931 K. 2019/1288 T. 18.2.2019

3) A decision of recognition and/or enforcement must have been received from the competent Turkish courts

Another general condition for the recognition and enforcement of foreign judgments in Turkey is obtaining an enforcement decision from the competent Turkish court. In other words, a judgment rendered by a foreign court cannot be directly executed within Turkey without first being approved by a Turkish judicial authority. This requirement reflects the fundamental principles of judicial independence and national sovereignty, ensuring that no foreign ruling takes effect in Turkey without review and confirmation by its own courts.

Special conditions

In addition to the general requirements, there are also special conditions that must be met for the recognition and enforcement of foreign court decisions in Turkey. The Turkish Supreme Court has clarified these principles through various precedents, outlining the key criteria and limitations governing the enforcement of foreign judgments under Turkish law as follows:

Articles 50-59 of law No. 5718 regulate the institutions of recognition and enforcement. Accordingly, the acceptance of a foreign court decision as final evidence or final judgment is dependent on the court’s determination that the foreign court decision meets the conditions for enforcement, and the decisions issued by foreign courts regarding civil cases and finalized according to the laws of that state. The execution of judgments in Turkey depends on the enforcement decision given by the competent Turkish court. Accordingly, there must be reciprocity between the state where the foreign judgment was given and Turkey, the decision must be related to an issue that is not within the exclusive jurisdiction of the Turkish courts, and the decision given in accordance with the defendant’s defense rights must not be contrary to Turkish public order.Recognition and Enforcement of Foreign Court Decisions in Turkey Supreme Court Decision – 11th CC., E. 2022/4561 K. 2022/6225 T. 26.9.2022

On the other hand, according to the relevant article of the law, the request for enforcement of foreign court decisions is accepted if the following conditions are met:

1) Principle of reciprocity

For the enforcement of foreign court decisions in Turkey, the existence of a reciprocity relationship between Turkey and the country where the judgment was rendered is one of the most significant requirements. This principle ensures mutual respect and cooperation between states regarding the execution of judicial decisions. In essence, Turkey enforces the court decisions of another country only if that country, in turn, recognizes or enforces Turkish court judgments under similar conditions.

Reciprocity may stem from three different legal sources:

1. International treaties — Some bilateral or multilateral agreements between Turkey and other states explicitly provide for the mutual enforcement of judgments.
2. Domestic legal provisions — A country’s internal legislation may allow for the enforcement of Turkish court decisions, even without a treaty.
3. De facto or judicial practice — Even in the absence of written agreements, consistent judicial precedents showing that Turkish judgments have been enforced abroad can establish de facto reciprocity.

It is important to note that the principle of reciprocity applies only to enforcement, not to recognition. Therefore, a foreign judgment may still be recognized in Turkey even if reciprocity cannot be proven — for instance, in divorce recognition cases where no execution or financial enforcement is involved.

In practice, Turkish courts carefully examine whether reciprocity exists before granting enforcement of foreign judgments in Turkey. For many countries, such as Germany, France, Italy, the United Kingdom, and the United States, reciprocity has been established through court practice or bilateral understanding. However, for states where this relationship is uncertain, the court may require additional evidence to confirm that Turkish judgments can be enforced in that jurisdiction.

The reciprocity rule reflects the principle of equality between sovereign states, preventing unilateral enforcement and ensuring that the recognition and enforcement of foreign judgments in Turkey operate on a balanced and reciprocal basis.

2) Authority must not be exceeded

The judgment must not concern a matter that falls within the exclusive jurisdiction of Turkish courts. Furthermore, if the defendant raises an objection, the foreign court must not have asserted jurisdiction arbitrarily in a dispute where there is no genuine connection between the case, the subject matter, or the parties and that foreign state. In other words, for the recognition and enforcement of foreign judgments in Turkey, the foreign court must have had a legitimate basis for exercising jurisdiction.

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3) The judgment must not be contrary to Turkish public order

One of the fundamental principles of Turkish law is that contracts, judicial decisions, and legal acts must not conflict with public order or moral values. Any foreign court judgment that contradicts the basic principles of Turkish law, culture, or public morality will be deemed legally invalid. For instance, if euthanasia is permitted in a foreign country and a related judgment is brought for enforcement in Turkey, it would be considered contrary to public order and therefore cannot be recognized or enforced.

Respecting public order ensures that the recognition and enforcement of foreign judgments in Turkey remain consistent with the country’s fundamental legal and ethical framework.

4) No violation of the right to a fair trial

Under the laws of the country where the foreign court decision was issued, if the person against whom enforcement is sought was not properly summoned, not duly represented, or if the judgment was rendered in absentia or in violation of procedural rights, the enforcement of the decision in Turkey will depend on the absence of valid objections. The party against whom enforcement is requested has the right to object to the recognition and enforcement of the foreign judgment. If the Turkish court finds that the objection is justified, the decision will not be recognized or enforced in Turkey.

This safeguard ensures that the recognition and enforcement of foreign court decisions in Turkey respect the fundamental right to a fair trial and due process under both Turkish and international legal standards.

Do the parties need to be Turkish for the enforcement of foreign court decisions?

The recognition and enforcement of foreign court decisions in Turkey do not depend on the nationality or citizenship of the parties. What matters is whether there is a legal interest or connection with Turkey. Even when both parties are foreign individuals or foreign companies, enforcement may still be requested if the judgment produces legal or financial effects within Turkey.

Such a connection typically exists when one of the parties resides in Turkey, owns property or assets located in the country, or when the execution of the foreign judgment requires an action before Turkish authorities—such as registration in the land or population registry. For example, if a couple obtained a divorce decree abroad and one spouse later moved to Turkey, that judgment must be recognized by a Turkish family court before it can take effect in official records. Likewise, a foreign company that wins a commercial lawsuit abroad against a Turkish debtor can file for the enforcement of a foreign judgment with debt collection in Turkey.

This principle reflects the international nature of private law and ensures access to justice in cross-border cases. As long as a legitimate link with Turkey can be demonstrated, the recognition and enforcement of foreign judgments in Turkey may proceed regardless of the parties’ nationality.

In order to decide on the recognition or enforcement of a foreign court judgment, the party to the judgment does not need to be a Turkish citizen. Even if the parties are not Turkish, they may request the enforcement or recognition of the foreign judgment, provided that they have legal interests.Recognition and Enforcement of Foreign Court Decisions in Turkey Supreme Court Decision – 2nd CC., E. 2008/19620 K. 2010/1034 T. 20.1.2010

Competent Court for the Recognition and Enforcement of Foreign Court Decisions in Turkey

The competent court for the recognition and enforcement of foreign court decisions in Turkey is the Court of First Instance (Asliye Hukuk Mahkemesi). Depending on the nature of the dispute, these may include family courts, commercial courts, or general civil courts of first instance. The type of court is determined by the subject matter of the foreign judgment.

According to Article 51/1 of Law No. 5718 on Private International Law and Procedural Law, enforcement proceedings must be filed before a court of first instance. Although the law does not distinguish between civil and commercial courts, this determination is made in line with the Turkish Code of Civil Procedure. If the dispute is of a commercial nature, the case should be heard before the commercial court of first instance rather than a general civil court.

The Court of Cassation (15th Civil Chamber, E. 2015/5244, K. 2015/6250, 8.12.2015) confirmed this interpretation, ruling that where both parties are traders and the foreign judgment concerns their commercial activities, the competent authority for enforcement of foreign judgments in Turkey is the commercial court of first instance.

In terms of territorial jurisdiction, the competent court is the one located in the place where the person against whom enforcement is sought resides or is domiciled in Turkey. If the defendant has no residence or habitual place in the country, the application can be filed before the courts of Ankara, Istanbul, or Izmir.

Procedure for the Recognition and Enforcement of Foreign Judgments in Turkey

Foreign court decisions that meet both the general and special requirements outlined above may be submitted to Turkish courts for enforcement. To initiate the recognition and enforcement procedure, the applicant must file a petition before the competent court of first instance, including the following documents:

• The officially certified original judgment or a duly approved copy issued by the competent authority of the country where the decision was rendered,
• A sworn Turkish translation of the judgment,
• And a certificate of finality, proving that the decision is final and binding under the laws of the foreign state.

After the petition is filed, the court notifies the respondent party of the hearing date and provides copies of the attached documents. The respondent may raise objections, claiming that the conditions for enforcement are not satisfied, that the judgment has already been partially or fully fulfilled, or that there exists a legal impediment to enforcement.

Following the hearing, the court may decide to grant enforcement in full or in part, or reject the application. Once a foreign judgment is granted enforcement, it gains the same legal effect as a domestic Turkish court ruling and can be executed through local enforcement offices.

Decisions rendered in recognition and enforcement cases are subject to appeal, and the appeal procedure follows the same rules as other civil cases. Importantly, the appeal suspends enforcement until the decision becomes final.

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Difference Between Recognition and Enforcement in Turkey

When dealing with foreign court judgments, it is essential to distinguish between recognition (tanıma) and enforcement (tenfiz), as these two legal mechanisms serve different purposes under Turkish law. Although they are closely related, the scope and legal consequences of each are distinct.

Recognition means that a foreign judgment is accepted as valid and produces legal effects within Turkey — but without making it enforceable. In other words, recognition allows the decision to be used as conclusive evidence or a binding determination before Turkish authorities. For example, when a couple obtains a foreign divorce judgment, they must request recognition in Turkey to update their civil status records and register the divorce in the national population registry. Recognition is therefore sufficient in cases where no performance or execution is required.

Enforcement, on the other hand, goes one step further. It transforms a foreign court judgment into one that can be executed in Turkey as if it were issued by a Turkish court. This applies to cases involving monetary awards, compensation, or obligations to perform. Once the Turkish court grants an enforcement decision, the judgment creditor may proceed with execution through Turkish enforcement offices, such as for collecting debts or seizing assets.

Under Law No. 5718 on Private International Law and Procedural Law, both recognition and enforcement of foreign judgments in Turkey require court approval. However, recognition does not require reciprocity between states, whereas enforcement generally does. Understanding this distinction helps foreign individuals and companies determine the correct procedure and avoid unnecessary delays or rejections during the process.

Timeline and Cost of Recognition and Enforcement Cases in Turkey

The recognition and enforcement of foreign court decisions in Turkey involve a judicial procedure whose duration and cost depend on the complexity of the case, the completeness of the submitted documents, and the conduct of the parties. Although the process follows similar stages nationwide, the overall timeline and expenses may vary between courts.

Timeline of the Procedure

In straightforward cases—where all documents are properly apostilled, translated, and certified—a recognition or enforcement judgment can typically be obtained within six to nine months. If the respondent raises objections or if the court needs to verify reciprocity with the foreign state, proceedings may extend to twelve to eighteen months. Common causes of delay include incomplete documentation, inaccurate translations, or jurisdictional disputes.

Following the first-instance ruling, either party may file an appeal and, if necessary, a further appeal before the Court of Cassation. These additional stages can extend the total duration, and enforcement remains suspended until the judgment becomes final.

Court Fees and Legal Costs

The cost of enforcement of foreign judgments in Turkey consists of court filing fees, translation and notarization expenses, and attorney fees. The applicable type of court fee in these cases has been the subject of significant debate under Turkish law. While some courts have traditionally applied a proportionate fee, calculated as a percentage of the claim’s value, others have applied a fixed fee, considering enforcement actions to be declaratory in nature.

Previously, the fixed-fee approach was used, reasoning that recognition and enforcement proceedings merely declare a foreign judgment enforceable without resolving the substantive dispute. However, the matter was revisited by the Turkish Constitutional Court in a significant decision published in 2025. In this ruling, the Court examined the issue from the perspective of constitutional rights, particularly the right to property and the right of access to justice. It ultimately concluded that the use of proportionate fees in enforcement proceedings does not violate these fundamental rights, confirming that such an approach remains compatible with the Turkish Constitution.

In conclusion, a uniform court practice has not yet been established. Accordingly, applicants should consult a Turkish lawyer experienced in the recognition and enforcement of foreign judgments to assess likely costs in their specific jurisdiction. Professional legal guidance helps ensure compliance with procedural requirements, minimizes the risk of rejection, and expedites the overall process.

Why You Should Work With a Lawyer in Turkey

The recognition and enforcement of foreign court decisions in Turkey is a highly technical process that can only be handled by lawyers licensed to practice in Turkey. Turkish procedural law requires that all filings, court appearances, and legal submissions be made through a licensed Turkish attorney. Therefore, foreign individuals and companies must appoint a lawyer who is registered with a Turkish Bar Association to represent them before the competent court.

Attempting to manage the process through debt collection agencies, or so-called international consultancy firms that are not authorized to practice law in Turkey can lead to serious legal and financial risks. These entities are not permitted to represent clients in Turkish courts, cannot sign pleadings, and are not recognized by judicial authorities. As a result, applications filed through such intermediaries are often rejected or delayed, causing unnecessary loss of time and money.

Working with an experienced Turkish law firm ensures that your case proceeds efficiently and in full compliance with Turkish legal standards. Licensed attorneys can:

• Identify the correct court and jurisdiction,
• Prepare and file all required documents properly (apostilles, translations, certifications),
• Handle objections and procedural issues before the court,
• Ensure the enforcement of foreign judgments in Turkey proceeds without risk.

Only lawyers authorized to practice in Turkey have the right to appear before courts, submit petitions, and execute enforcement proceedings. So, choosing a trusted Turkish law firm therefore guarantees not only professional representation but also legal certainty, confidentiality, and the protection of your rights throughout the entire enforcement process.

Frequently Asked Questions

Which law regulates the Recognition and Enforcement of Foreign Court Decisions in Turkey?

The recognition and enforcement of foreign court decisions in Turkey are governed by Law No. 5718 on Private International Law and Procedural Law (MÖHUK). This law outlines the procedural and substantive rules applicable to both civil judgments and criminal decisions concerning personal rights, establishing the framework for how foreign rulings can take legal effect in Turkey.

Are US and UK judgments enforceable in Turkey?

Yes. US, UK, and other foreign court judgments can be enforced in Turkey once a recognition and enforcement judgment is obtained from a Turkish court. The process requires demonstrating that the foreign decision is final, not contrary to public order, and that there is reciprocity between Turkey and the country where the judgment originated.

How long does it take to enforce a foreign judgment in Turkey?

The duration of enforcement proceedings depends on the complexity of the case and whether objections are raised by the opposing party. On average, the process may take around one year. Delays often occur when documents lack an apostille or proper translation. Working with a lawyer in Turkey experienced in enforcement cases can significantly shorten the timeline.

Which types of foreign court decisions can be recognized and enforced in Turkey?

Foreign court decisions relating to civil and commercial disputes, as well as personal rights in criminal cases, can be recognized and enforced in Turkey. This includes divorce judgments, compensation awards, debt collection rulings, and inheritance decisions. However, judgments on matters falling under the exclusive jurisdiction of Turkish courts (e.g., real estate located in Turkey) cannot be enforced.

Do I need a lawyer in Turkey to enforce a foreign judgment?

Yes. Foreign individuals or companies must be represented by a licensed Turkish attorney before the competent court. A lawyer will ensure that all documents (such as the certified judgment, certificate of finality, and apostilled translation) meet the procedural requirements for recognition and enforcement of foreign judgments in Turkey.

Conclusion

The recognition and enforcement of foreign court decisions in Turkey require not only a clear understanding of the law but also strict compliance with procedural formalities. Each stage — from verifying the finality of the judgment to preparing translations and submitting documents to the competent court — must be handled with precision. Even a minor procedural error can cause months of delay or jeopardize the enforceability of the foreign judgment.

For this reason, it is essential to work with a lawyer licensed to practice in Turkey. Only Turkish attorneys are authorized to represent clients before local courts and enforcement offices. Engaging an experienced Turkish law firm ensures that your case proceeds efficiently, your documents are properly prepared, and your rights are fully protected under Turkish law.

Whether you are seeking to enforce a foreign commercial judgment, a divorce decree, or a compensation order, professional legal guidance is the key to achieving a secure and timely result. With the right legal support, you can confidently navigate the enforcement process and ensure that your foreign court decision has full effect in Turkey.