How to Recognize and Enforce a Foreign Court Judgment in Turkey — 2026 Guide

How to Recognize and Enforce a Foreign Court Judgment in Turkey — 2026 Guide

For a divorce, custody, inheritance, or commercial judgment obtained abroad to produce legal effect in Turkey, a recognition or enforcement action generally must be filed before a Turkish court. This process comes up often in regions like Antalya, home to a large population of foreign residents and investors.

What Is the Difference Between Recognition and Enforcement?

Recognition allows the res judicata or conclusive evidentiary effect of a foreign judgment to be accepted in Turkey; it is generally sufficient for matters such as having a divorce or custody decision entered into the civil registry. Enforcement is required when the judgment needs to be carried out by compulsory execution in Turkey (for example, enforcing a monetary judgment through execution proceedings).

What Requirements Must Be Met?

Under Article 54 of Turkish Private International and Procedural Law No. 5718 ("PIL"), an enforcement request can be granted only if:

• There is reciprocity between Turkey and the state where the judgment was rendered,
• The judgment was not rendered on a matter falling within the exclusive jurisdiction of Turkish courts,
• The judgment is not manifestly contrary to Turkish public order,
• The person against whom enforcement is sought was duly summoned or represented under the law of that country, or did not object to the contrary, and
• The judgment has become final under the law of the country where it was rendered.

Which Court Has Jurisdiction?

Recognition and enforcement actions are heard before the civil court of first instance (asliye hukuk mahkemesi). Territorial jurisdiction lies with the court of the domicile, or failing that, the habitual residence in Turkey of the person against whom enforcement is sought; if that person has neither in Turkey, the action may be filed before the courts of Ankara, Istanbul, or Izmir.

Does the Turkish Court Re-Examine the Merits?

No. In recognition and enforcement proceedings, the Turkish court does not review whether the foreign judgment was correctly decided on the merits (the prohibition on révision au fond); it only examines whether the formal and public-order requirements listed above are satisfied.

What Documents Are Required?

• The original or a certified copy of the foreign judgment (apostilled)
• A document evidencing that the judgment has become final
• A certified Turkish translation of the judgment and supporting documents by a sworn translator
• Identification/passport details of the parties
• A notarized power of attorney if the case is pursued through a lawyer

Is There a Special Route for Foreign Divorce Decrees?

For certain divorce decrees obtained abroad by Turkish citizens, where the conditions of Article 27 of PIL Law No. 5718 are met, it may be possible to apply for administrative recognition through the civil registry office or a consulate without going to court. Whether this route is available depends on the nature of the decision and the specific circumstances, so we recommend having it assessed by a lawyer in advance.

Frequently Asked Questions

Is a foreign divorce decree automatically valid in Turkey?

No. As a rule, a recognition action must be filed before a Turkish court, or (where the conditions are met) an administrative recognition application must be made; a foreign judgment is not automatically entered into Turkish civil registry records.

How long does an enforcement action take?

The duration varies depending on the court's caseload, objections raised by the other party, and whether the documents are submitted complete, but a well-prepared file can significantly speed up the process.

Can the other party object to the action?

Yes. The party against whom enforcement is sought can object to the action by arguing that the requirements set out in PIL Law No. 5718 have not been met.

Source: Turkish Private International and Procedural Law No. 5718 ("MÖHUK"), Arts. 50–59.

This content is provided for general informational purposes only and does not constitute legal advice. Recognizing or enforcing a foreign court judgment in Turkey is a technical process whose outcome depends on the specifics of each case; we recommend consulting a lawyer before filing.