Won a case abroad but the assets or the other party are in Türkiye? A foreign judgment doesn't enforce itself — you generally need a Turkish court to recognise and enforce it first. Here's how that works.
Recognition vs enforcement
There are two related concepts. Recognition means a Turkish court accepts the foreign judgment as valid; enforcement (tenfiz) means it can be executed in Türkiye, for example against assets. For money judgments you usually need enforcement; for status matters (like a divorce) recognition may be enough.
What the court looks at
A Turkish court reviewing a foreign judgment typically checks conditions such as:
- Reciprocity or a treaty basis with the country of origin (depending on the matter);
- That the foreign court had proper jurisdiction;
- That the defendant's basic procedural rights were respected (proper notice and a chance to be heard);
- That the judgment is final and does not conflict with Turkish public policy.
The court does not re-try the merits — it reviews whether these gateway conditions are met.
Most refusals turn on procedural-rights or public-policy grounds. Anticipating these — and documenting that the foreign process was fair — is where cases are won or lost.
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The process in outline
- Obtain a final, certified copy of the foreign judgment with official translation;
- File a recognition/enforcement action in the competent Turkish court;
- Address any objections (jurisdiction, notice, public policy);
- Once granted, proceed to execution against assets if needed.
Common obstacles
Cases stumble on missing finality, defects in how the defendant was served abroad, incomplete certification/translation, or public-policy arguments. Preparing the file to pre-empt these is the practical key to success.
Frequently asked questions
What is the difference between recognition and enforcement, and which one do I need?
Recognition means a Turkish court accepts your foreign judgment as valid, while enforcement (tenfiz) lets it actually be executed in Türkiye, for example against the other party's assets. For money judgments you normally need enforcement; for status matters such as a divorce, recognition may be enough. A local disputes lawyer can confirm which route fits your specific judgment.
Does Türkiye require a treaty or reciprocity with the country where I won my case?
A Turkish court reviewing a foreign judgment typically looks for a treaty basis or reciprocity with the country of origin, depending on the type of matter. Because how this is assessed can vary by situation, it is worth having a lawyer check the position for your particular country before you file.
Will the Turkish court reopen the facts and let the other side argue the case again?
No. The court does not re-try the merits; it reviews gateway conditions such as proper jurisdiction, respect for the defendant's procedural rights, finality, and consistency with Turkish public policy. The other side can raise objections, but only within those limits rather than by re-arguing who was right.
Why do enforcement cases get refused, and how can I reduce that risk?
Most refusals turn on procedural-rights or public-policy grounds, or on practical defects such as missing finality, faulty service on the defendant abroad, or incomplete certification and translation. Preparing the file to pre-empt these objections, and documenting that the foreign process was fair, is where these cases are typically won or lost, so build the file carefully with a lawyer from the start.
Will the Turkish court re-hear my case?
No — it reviews the gateway conditions, not the merits, though the other side may raise objections within those limits.
Do I need the original judgment?
You generally need a final, certified copy with official translation; your lawyer will confirm the exact form.
How long does it take?
It varies with the court and whether the other side contests; an uncontested, well-prepared file is faster.
Official sources
Rules, fees and thresholds change. Confirm anything in this guide with the official source before you act.
- Göç İdaresi Başkanlığıimmigration authority
- Gelir İdaresi Başkanlığıtax authority
- Türkiye Barolar Birliğibar association — verify a lawyer
- Tapu ve Kadastroland registry