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Gurbuz Law

Enforcing Foreign Judgments and Arbitral Awards in Türkiye: Procedure, Evidence and Interim Relief

A foreign court judgment is not directly enforceable in Türkiye; an enforcement judgment is generally required under Turkish private international law. Foreign arbitral awards are enforced under the New York Convention or applicable Turkish statutes. Success depends not only on the decision, but also finality, due service, apostille and translation, competent court, public policy and…

Published by: Gurbuz Law

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Legal position last verified: 1 September 2026.

A foreign court judgment is not directly enforceable in Türkiye; an enforcement judgment is generally required under Turkish private international law. Foreign arbitral awards are enforced under the New York Convention or applicable Turkish statutes. Success depends not only on the decision, but also finality, due service, apostille and translation, competent court, public policy and a strategy for locating Turkish assets.123

This guide is for foreign creditors, arbitration parties, international counsel, funds and recovery teams pursuing assets in Türkiye.

Core conclusion: Enforcement proceedings and asset recovery should be planned as one project; recognition of the decision matters only if assets are identified, preserved and reachable.

Who is this guide for?

This guide is for foreign creditors, arbitration parties, international counsel, funds and recovery teams pursuing assets in Türkiye.

Decision summary in one minute

Decision type Required route Core documents Main refusal risk
Foreign court judgment Recognition/enforcement Decision, finality, service PILA conditions
Foreign arbitral award Enforcement Arbitration agreement, award NY Convention defences
Status judgment Often recognition Decision and finality Public policy/special rules
Money judgment Enforcement plus execution Amount, interest, costs Uncertainty and recovery
Interim protection Attachment/injunction Claim and risk evidence Security and prima facie proof

1. Recognition versus enforcement

Recognition gives a foreign judgment res judicata or conclusive-evidence effect in Türkiye; enforcement gives it coercive executability. A money or performance judgment normally requires enforcement, while status or res judicata may require recognition only.4

The court may characterise the request, but strategy, fees, jurisdiction and remedy should be clear from the outset.5

2. Conditions for foreign court judgments

The decision must be a final civil judgment of a foreign court and satisfy the statutory tests on reciprocity, exclusive/exorbitant jurisdiction, defence rights and public policy.6

The Turkish court does not retry the merits, but reviews refusal grounds. Service and opportunity-to-be-heard evidence can therefore be as important as the judgment.7

3. Foreign arbitral awards and the New York Convention

Türkiye applies the New York Convention subject to its commercial and reciprocity reservations. Valid arbitration agreement, due process, jurisdiction, procedure, binding effect and public policy are principal defence areas.89

The enforcement court does not review substantive correctness. Public policy should be applied narrowly, though sanctions, corruption, arbitrability and fundamental procedural guarantees can matter.1011

4. Documents, apostille, translation and finality

A duly authenticated original or copy, evidence of finality and certified Turkish translation are required, with apostille or consular legalisation depending on origin. For awards, the arbitration agreement and authenticated award are central.12

Finality or binding effect should be explained under the law of origin. Electronic judgments and online verification need an evidential chain acceptable to the Turkish court.13

5. Jurisdiction, interim attachment and assets

Jurisdiction is generally connected to the debtor’s domicile, residence or assets in Türkiye. Pre-filing asset research should identify bank accounts, real estate, shares, receivables, vessels or other assets.14

Interim attachment or injunction can preserve effectiveness, but requires a prima facie claim, maturity/risk analysis and security. A foreign decision does not automatically produce attachment.15

6. Execution, interest and costs after enforcement

Once the enforcement judgment is final, execution proceeds as a Turkish judgment. Ambiguity in currency, interest commencement, rate, costs or partial payments can create execution disputes.1617

Restructuring, insolvency and asset-dissipation risk should be monitored independently from the enforcement timetable. Settlement, preservation and execution can run as coordinated tracks.1819

Documents and evidence the company should prepare

  • Authenticated judgment or award
  • Finality or binding-effect certificate
  • Service and due-process records
  • Apostille or consular legalisation
  • Certified Turkish translation
  • Arbitration agreement
  • Debtor and asset research
  • Interest, costs and payment calculation

Contract and governance controls

  • Arbitration/court jurisdiction
  • Notice address and method
  • Language and record retention
  • Interim-relief rights
  • Enforcement costs
  • Interest and currency
  • Asset and information undertakings
  • Settlement and payment plan

Red flags and recurring mistakes

  • Leaving finality evidence until late
  • No documentary proof of service
  • Separating enforcement from asset research
  • Expecting merits review
  • Using public policy as a general appeal
  • Failing to calculate currency and interest

Three practical scenarios

1. English money judgment

Finality and service evidence are apostilled and translated, interim attachment over Turkish shares is assessed, and interest is calculated from the judgment.

2. ICC arbitral award

The arbitration agreement, award, service and tribunal jurisdiction are filed. Public-policy and due-process objections are addressed without inviting merits review.

3. Risk of asset dissipation

A prima facie evidence and security file is prepared alongside the enforcement action, asset research is updated and execution is planned before judgment.

A 30–60–90-day implementation plan

Days 1–30 — scope and visibility

  • Build the recognition, enforcement and recovery scope and role matrix.
  • Collect the relevant contracts, permissions, data and decision records.
  • Assign owners to urgent gaps and threshold questions.

Days 31–60 — evidence and contracting

  • Complete missing permissions, policies, schedules and records.
  • Obtain management approval for the decision matrix.
  • Test group-company and supplier flows against the chosen model.

Days 61–90 — testing and governance

  • Run a practical scenario or tabletop exercise.
  • Report open risks with owners and closure dates.
  • Establish annual and event-driven review triggers.

Frequently asked questions

Can a foreign judgment be executed directly in Türkiye?

No. A Turkish enforcement judgment is generally required.

What is the difference between recognition and enforcement?

Recognition gives res judicata effect; enforcement gives coercive executability.

Which regime applies to an arbitral award?

The New York Convention or Turkish statutes apply depending on the award and arbitration.

Will the Turkish court retry the merits?

No. It generally reviews only enforcement conditions and defences.

Is apostille always required?

Apostille or consular legalisation depends on the country and applicable treaty.

Can interim attachment be obtained before enforcement?

Potentially, subject to the claim, risk and security requirements; it is not automatic.

What does public policy mean?

A manifest conflict with fundamental principles of the Turkish legal order, applied narrowly.

What happens after enforcement?

Once final, the enforcement judgment supports execution against Turkish assets.

Conclusion

Enforcement is not a translation exercise. Finality, service, defences, assets and interim protection must form one recovery strategy if a foreign decision is to produce economic value.

This article provides general information only. It is not a legal opinion for a particular company, transaction, tax position, licence application or dispute. Applicable sector, tax, employment and regulatory rules require a fact-specific review.

Bibliography

Footnotes

  1. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  2. Recognition and Enforcement in Turkish Private International Law https://doi.org/10.54704/akdhfd.1823446 accessed 1 September 2026. Current doctrinal issues in recognition and enforcement of foreign judgments.↩︎

  3. Enforcement and Provisional Attachment in Türkiye https://doi.org/10.26650/ppil.2021.41.2.997201 accessed 1 September 2026. Academic analysis of the relationship between enforcement and provisional attachment.↩︎

  4. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  5. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  6. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  7. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  8. Recognition and Enforcement in Turkish Private International Law https://doi.org/10.54704/akdhfd.1823446 accessed 1 September 2026. Current doctrinal issues in recognition and enforcement of foreign judgments.↩︎

  9. Enforcement and Provisional Attachment in Türkiye https://doi.org/10.26650/ppil.2021.41.2.997201 accessed 1 September 2026. Academic analysis of the relationship between enforcement and provisional attachment.↩︎

  10. Recognition and Enforcement in Turkish Private International Law https://doi.org/10.54704/akdhfd.1823446 accessed 1 September 2026. Current doctrinal issues in recognition and enforcement of foreign judgments.↩︎

  11. Enforcement and Provisional Attachment in Türkiye https://doi.org/10.26650/ppil.2021.41.2.997201 accessed 1 September 2026. Academic analysis of the relationship between enforcement and provisional attachment.↩︎

  12. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  13. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  14. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  15. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  16. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  17. Türk Borçlar Kanunu No 6098 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6098.pdf accessed 1 September 2026. Contract, representation, services, liability, termination and compensation provisions.↩︎

  18. Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun No 5718 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.5718.pdf accessed 1 September 2026. Applicable law, international jurisdiction, recognition and enforcement.↩︎

  19. Türk Borçlar Kanunu No 6098 https://www.mevzuat.gov.tr/mevzuatmetin/1.5.6098.pdf accessed 1 September 2026. Contract, representation, services, liability, termination and compensation provisions.↩︎

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About this study

Published by
Gurbuz Law
First published
23 September 2026
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Scope and currency

This study is provided for general information only; it is not legal advice on a specific matter. Legislation, case law and practice may have changed since publication, and the current position should be assessed separately.

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