Business · Türkiye

Enforcing a foreign court judgment in Türkiye

BRBy Brisamo editorial·Updated June 2026·8 min read

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.

Public policy is the usual sticking point

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.

Need to enforce a judgment in Türkiye?

Get matched with disputes lawyers in Istanbul — free, no obligation.

Get matched

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

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.

BR
Brisamo editorial
General information, not legal advice

This guide is general information. For advice on your situation, get matched with a firm — free.

Find a lawyer →
Get matched with a lawyer — free