Enforcement Of Foreign Arbitral Awards In Turkey

Abstract

This article explains how a foreign arbitral award is recognised and enforced in Türkiye, with particular attention to the 1958 New York Convention, Türkiye's reciprocity and commercial reservations, the alternative regime in Articles 60 to 63 of the Code on Private International Law and International Civil Procedure No. 5718, and the distinction between enforcement and a forbidden review of the merits. It addresses the competent court, Article IV filing documents, Article V defences, public order, arbitrability, appeal, interim protection and execution against assets. It also identifies the separate position of awards seated in Türkiye under International Arbitration Law No. 4686. The analysis is designed for foreign companies, award creditors, in-house counsel and transaction teams that need a realistic Turkish enforcement plan.