Enforcing a Foreign Court Judgment in Turkey: Conditions, Procedure and Reciprocity

A money judgment from a foreign court can be executed in Turkey (Türkiye) only after a Turkish court has issued an enforcement decision (tenfiz kararı). The Turkish court does not rehear the case. It checks four things: that the judgment is final; that reciprocity exists between Turkey and the country of origin; that the judgment does not concern a matter reserved to Turkish courts and is not manifestly contrary to public order; and that the defendant's right to be heard was respected (Law No. 5718, Art. 50 and 54). Once the enforcement decision is final, the foreign judgment is executed through the Turkish enforcement offices like a domestic judgment.

This guide is for creditors — companies and individuals — who hold or expect a foreign judgment against a debtor with assets in Turkey. It explains the conditions, the procedure, the documents, the costs and time involved, how to secure assets in the meantime, and the alternative of suing in Turkey directly.

• Legal basis: Act on Private International and Procedural Law (No. 5718), Art. 50–59; for arbitral awards, Art. 60–63 and the New York Convention.
• Scope: final judgments of foreign courts in civil matters, and rulings on personal rights in criminal judgments (Art. 50).
• Court: the civil court of first instance at the debtor's domicile or residence in Turkey; otherwise Ankara, Istanbul or Izmir (Art. 51).
• Conditions: reciprocity; no exclusive Turkish jurisdiction or exorbitant foreign jurisdiction; no manifest breach of public order; due process for the defendant (Art. 54).
• No review of the merits.
• Defences: only that the conditions are not met, or that the judgment has been satisfied or cannot be performed (Art. 55(2)).
• Appeal suspends execution (Art. 57(2)).

Legal status of this guide. It reflects Law No. 5718 as currently in force. Bilateral and multilateral treaties to which Turkey is a party take precedence over these rules. Whether reciprocity exists with a particular country, and the court fees payable, depend on case law and current tariffs and should be confirmed for each case. Last updated: October 2026.

In this guide

• Why an enforcement decision is needed
• Which judgments can be enforced
• The four conditions
• Reciprocity in practice
• Public order: what it does and does not cover
• The procedure, step by step
• Documents
• Securing assets before the decision
• After the decision: execution
• Foreign arbitral awards
• The alternative: suing in Turkey
• Frequently asked questions

Why an enforcement decision is needed

The execution in Turkey of judgments given by foreign courts in civil cases, and final under the law of that state, depends on an enforcement decision by the competent Turkish court (Art. 50(1)). Without it, a Turkish enforcement office will not act on a foreign judgment, however clear and final it is.

Two related concepts should be distinguished:

• Enforcement (tenfiz) — needed where the judgment orders something to be performed: payment of a debt, damages, costs, delivery of goods.
• Recognition (tanıma) — needed where the judgment is to be relied on as a final decision or conclusive evidence, without execution: for example a declaratory judgment or a change of civil status. Recognition requires the same conditions except reciprocity (Art. 58(1)). For status judgments see recognition of a foreign divorce in Turkey.

A foreign judgment that has not yet been declared enforceable is not without value: it may be used as evidence in Turkish proceedings and can support an application for interim protection.

Which judgments can be enforced

• Judgments of courts. The decision must come from a body exercising judicial authority in the state of origin. Court-approved settlements and similar acts are treated according to their effect under the foreign law.
• Civil matters. Commercial, contractual, tort, family and inheritance matters qualify. Tax, administrative and criminal judgments do not — except that rulings on personal rights contained in a foreign criminal judgment, such as an award of damages to the victim, may be enforced (Art. 50(2)).
• Final. The judgment must be final under the law of the state of origin — no ordinary appeal available or pending (Art. 50(1)). Provisional and interim measures ordered by foreign courts, and judgments that are enforceable but still under appeal, do not qualify.
• Default judgments qualify, subject to the due-process condition discussed below.
• Partial enforcement is possible: the applicant may ask for enforcement of part of the judgment, and the court may grant the request in whole or in part (Art. 52(c), 56).

The four conditions

The competent court grants enforcement where the following conditions are met (Art. 54(1)):

Art. 54(1)	Condition	Examined
(a)	Reciprocity — an agreement between Turkey and the state of origin based on reciprocity, or a statutory provision or de facto practice in that state allowing enforcement of Turkish court judgments	By the court of its own motion
(b)	Jurisdiction — the judgment was not given on a matter within the exclusive jurisdiction of Turkish courts; and, provided the defendant objects, was not given by a court that assumed jurisdiction although it had no real connection with the subject matter or the parties	Exclusive jurisdiction: by the court; exorbitant jurisdiction: only on the defendant's objection
(c)	Public order — the judgment is not manifestly contrary to public order	By the court of its own motion
(ç)	Due process — the person against whom enforcement is sought was duly summoned to the foreign court or represented there, and judgment was not given in their absence in breach of that state's law — and that person has not objected on one of these grounds before the Turkish court	Only on the defendant's objection

The court does not examine whether the foreign court applied the right law, assessed the evidence correctly or reached the right result. This prohibition on reviewing the merits (révision au fond) is the central principle of the system. The defendant's objections are limited accordingly: that the conditions for enforcement are not present, or that the foreign judgment has been wholly or partly performed, or that a reason preventing its performance has arisen (Art. 55(2)).

Exclusive jurisdiction of Turkish courts covers, in particular, actions concerning rights in rem over immovable property located in Turkey. A foreign judgment purporting to determine ownership of Turkish real estate will not be enforced on that point. Ordinary commercial and contractual claims are not within any exclusive jurisdiction.

Reciprocity in practice

Reciprocity is usually the decisive question, and it can be established in three ways:

1. Treaty reciprocity — a bilateral treaty on judicial assistance, or a multilateral convention to which both states are party, providing for mutual recognition and enforcement.
2. Statutory reciprocity — a provision in the law of the state of origin under which Turkish judgments can be enforced on conditions no more onerous than those Turkey applies.
3. De facto reciprocity — actual practice in the state of origin of enforcing Turkish judgments.

For many European and other countries, Turkish courts have accepted reciprocity on one of these bases, and there is settled case law to rely on. For others the position is unclear or has been denied — in particular where the foreign system re-examines the merits of Turkish judgments or requires a fresh action. Reciprocity is assessed as at the time of the enforcement proceedings, for the type of judgment in question.

Before starting, the creditor's lawyer should identify the basis of reciprocity for the specific country and gather supporting material: the treaty text, the relevant foreign statute, or decisions of that country's courts enforcing Turkish judgments. Where needed, the Turkish court seeks information through the Ministry of Justice.

Public order: what it does and does not cover

The law requires that the judgment not be manifestly contrary to public order (Art. 54(1)(c)). The test concerns the consequences of giving effect to the judgment in Turkey, not the reasoning of the foreign court, and it is applied narrowly.

• Not a public-order problem in itself: that the foreign law differs from Turkish law; that a Turkish court would have decided differently; that the foreign court applied a law other than the one Turkish conflict rules would designate; that the judgment contains no or brief reasons — a point settled by the Court of Cassation, which held that the absence of reasoning does not by itself prevent enforcement.
• Potential problems: a judgment obtained by fraud; a fundamental denial of the right to a fair hearing; awards that conflict with basic principles of Turkish law or morality; awards of punitive or multiple damages to the extent that they go beyond compensation; conflict with a prior Turkish judgment between the same parties on the same matter.

Where only part of a judgment raises a public-order concern, the remainder can be enforced.

The procedure, step by step

1. Standing. Anyone with a legal interest in the enforcement of the judgment may apply (Art. 52).
2. Competent court. The civil court of first instance (Art. 51(1)); for commercial judgments the application is in practice brought before the commercial court of first instance, and for family judgments before the family court. Venue: the domicile in Turkey of the person against whom enforcement is sought; if none, their place of residence; if they have neither, one of the courts of Ankara, Istanbul or Izmir (Art. 51(2)).
3. Petition (Art. 52), with as many copies as there are opposing parties, stating: the names and addresses of the applicant, the opposing party and any legal representatives and lawyers; the state and court that gave the judgment, its date and number, and a summary of its operative part; and, if enforcement of only part is sought, which part.
4. Fees and security. Court fees and an advance on costs are payable on filing; whether a proportional or a fixed fee applies has been treated differently over time and should be checked against current practice. A foreign claimant must provide security for costs unless exempted on the basis of reciprocity or a treaty — the Hague Convention on Civil Procedure being the most common basis.
5. Service and hearing. The petition is served on the opposing party together with the hearing date, and the request is examined and decided under the simplified procedure (Art. 55(1)). Service abroad, where the debtor has no address in Turkey, takes place through official channels and can add months.
6. Defence. Limited to the grounds in Art. 55(2).
7. Decision. The court orders enforcement in whole or in part, or dismisses the request. The decision is written beneath the foreign judgment, sealed and signed by the judge (Art. 56).
8. Appeal. Decisions granting or refusing enforcement are subject to appeal under the general provisions, and the appeal suspends execution (Art. 57(2)). Execution therefore becomes possible only when the enforcement decision is final.

Duration. An uncontested application with a debtor served in Turkey can be decided at first instance within several months; a contested one, with appeal, commonly takes considerably longer than a year. This timetable is the main reason to think about interim protection from the outset.

Documents

The petition must be accompanied by (Art. 53):

• the original of the foreign judgment, duly certified by the authorities of that state, or a copy certified by the judicial body that gave it, with a certified translation;
• a document or letter showing that the judgment is final, duly certified by the authorities of that state, with a certified translation.

In practice:

• both documents bear an apostille, or consular legalisation for states outside the Apostille Convention;
• translations are made by a sworn translator and notarised in Turkey, or certified by a Turkish consulate;
• for default judgments, add proof that the defendant was served with the document instituting the proceedings and with the judgment;
• add evidence of reciprocity where it is not already established in case law;
• the lawyer needs a power of attorney issued by a Turkish notary or consulate, or by a foreign notary with apostille and translation; for a company, with proof of the signatories' authority.

Securing assets before the decision

Because the appeal suspends execution, a debtor has ample time to move assets. Two tools are available:

• Precautionary attachment (ihtiyati haciz). A creditor with a due, unsecured money claim may ask the court to attach the debtor's assets provisionally, on showing the claim to be probable and usually against security. A final foreign judgment is strong evidence for this purpose. The attachment must be followed by proceedings within the statutory period.
• Interim injunction (ihtiyati tedbir) in non-monetary matters.

Before applying, investigate the debtor's assets as far as public sources allow: trade registry records, land registry searches where a legitimate interest is shown, known bank relationships, receivables from Turkish customers.

After the decision: execution

Foreign judgments declared enforceable are executed like judgments given by Turkish courts (Art. 57(1)):

• the creditor applies to an enforcement office, which issues an enforcement order to the debtor to pay within the statutory period;
• if the debtor does not pay, assets are attached and sold — bank accounts, receivables, vehicles, real estate, company shares;
• the debtor's defences at this stage are narrow, since the debt has been established by judgment;
• currency: a judgment in foreign currency can be executed as such, with payment in Turkish lira at the rate chosen by the creditor in accordance with the Code of Obligations — the due date or the date of actual payment;
• interest: the interest awarded in the foreign judgment is covered by the enforcement decision; default interest thereafter follows Turkish rules;
• limitation: judgments are subject to a ten-year limitation period for execution, renewed by each enforcement step.

Foreign arbitral awards

Awards made by arbitral tribunals abroad follow a separate and generally more favourable regime:

• Turkey is a party to the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, which takes precedence where it applies; Law No. 5718, Articles 60–63, applies otherwise.
• Arbitral awards that are final and enforceable, or binding on the parties, may be enforced (Art. 60(1)).
• The application is made by petition to the civil court of first instance of the place agreed in writing by the parties; failing agreement, the court of the award debtor's domicile in Turkey, or of their residence, or of the place where assets subject to execution are located (Art. 60(2)).
• The applicant submits the original or a certified copy of the arbitration agreement or clause, the original or a certified copy of the award that has become final and enforceable or binding, and certified translations of both (Art. 61).
• There is no reciprocity requirement of the kind that applies to court judgments between Convention states, and the grounds for refusal are limited to those in the Convention — invalid arbitration agreement, lack of proper notice, excess of mandate, irregular composition or procedure, an award not yet binding or set aside, non-arbitrability and public policy.

For cross-border contracts with Turkish counterparties, this is a strong reason to agree on arbitration rather than on the courts of a country whose reciprocity with Turkey is uncertain.

The alternative: suing in Turkey

Where reciprocity is doubtful, where the foreign judgment was given in default without clear proof of service, or where no judgment has yet been obtained, a fresh action before the Turkish courts may be the better course:

• Turkish courts have international jurisdiction on the basis of the domestic rules on venue — in particular the defendant's domicile in Turkey, the place of performance of a contract, or the place where a tort was committed or the damage occurred (Law No. 5718, Art. 40);
• the parties' choice of foreign law is respected in contractual matters, and the foreign judgment, if any, can be produced as evidence;
• commercial claims require mandatory mediation before filing;
• for an undisputed money claim, enforcement proceedings without judgment can be started directly at an enforcement office; see payment orders in Turkey and how to object for how that procedure works from the debtor's side;
• a valid exclusive jurisdiction or arbitration clause in favour of another forum may prevent a Turkish action, so check the contract first.

Holding a foreign judgment or award against a debtor in Turkey? Send a copy of the judgment, tell us which country it comes from and what you know about the debtor's assets. Message Yayla Law on WhatsApp or use the contact form. Reciprocity and asset protection are the first two questions.

Frequently asked questions

Can a foreign court judgment be enforced in Turkey?

Yes, once a Turkish court has issued an enforcement decision. The judgment must be final, reciprocity must exist with the country of origin, it must not fall within the exclusive jurisdiction of Turkish courts or be manifestly contrary to public order, and the defendant's right to be heard must have been respected.

Does the Turkish court re-examine the case?

No. The court does not review the merits, the evidence or the law applied by the foreign court. It examines only the statutory conditions for enforcement, and the debtor's defences are limited to those conditions and to performance of the judgment.

What is reciprocity, and how is it proved?

It means that Turkish judgments can be enforced in the country of origin. It can rest on a treaty, on a provision of that country's law, or on its courts' actual practice. It is shown by the treaty text, the foreign statute or court decisions, and by Turkish case law accepting it.

Which court do I apply to?

The civil court of first instance — in practice the commercial court for commercial judgments — at the debtor's domicile or residence in Turkey. If the debtor has neither, the application may be made in Ankara, Istanbul or Izmir.

What documents are required?

The certified original or certified copy of the judgment and a document showing that it is final, both certified by the authorities of the state of origin, with apostille or legalisation and certified Turkish translations, together with a power of attorney.

How long does enforcement of a foreign judgment take in Turkey?

Several months at first instance where the debtor is served in Turkey and does not seriously contest; more than a year where the application is contested and appealed, since an appeal suspends execution.

Can I freeze the debtor's assets while the case is pending?

Yes. A precautionary attachment can be requested on the basis of a due money claim shown to be probable, usually against security. A final foreign judgment is strong evidence in support.

Can a default judgment be enforced?

Yes, provided the defendant was duly summoned under the law of the foreign court. If the defendant objects before the Turkish court that they were not properly served or represented, and that is established, enforcement is refused.

Are foreign arbitral awards easier to enforce than court judgments?

Generally yes. Under the New York Convention no reciprocity of the kind required for court judgments needs to be proved between contracting states, and the grounds for refusal are limited.

Legal basis and sources

• Act on Private International and Procedural Law No. 5718, Articles 40 and 50–63 — official consolidated text at mevzuat.gov.tr.
• Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958).
• Hague Convention on Civil Procedure (1954); Hague Apostille Convention (1961).
• Enforcement and Bankruptcy Law No. 2004 (execution; precautionary attachment).

This article provides general legal information on Turkish law as of October 2026. It is not legal advice. Reciprocity must be assessed for the specific country and type of judgment.