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Cross-border debt recovery

Recognition and Enforcement of Foreign Judgments and Arbitral Awards in Türkiye

If you hold an unpaid court judgment or arbitral award from outside Türkiye, you cannot enforce it directly against a debtor or assets here — a Turkish court must first give it effect through recognition (tanıma) or enforcement (tenfiz) under MÖHUK (Law No. 5718). Once a court grants tenfiz, the decision can be turned into Turkish enforcement proceedings (icra takibi) to collect. This page is general information about Turkish law, not legal advice.

Certified cross-border legal documents on a desk.
Won abroad, collected hereA foreign judgment or award is recognised and enforced in Türkiye through tenfiz proceedings.
MÖHUK (Law 5718)
Foreign court judgments are recognised and enforced under arts ~50-59; foreign arbitral awards under arts ~60-63, alongside the 1958 New York Convention.
No re-trial of the merits
A Turkish court reviews a set list of conditions only — it does not re-examine the underlying dispute (no révision au fond).
Reciprocity (judgments)
For court judgments, MÖHUK 54 requires reciprocity — by treaty, statute, or de facto practice — between Türkiye and the country of origin.
tenfiz then icra
The court's enforcement decision is what lets you open Turkish enforcement proceedings (icra takibi) against the debtor's assets.

Who this is for

This page is for a foreign creditor — often a company, investor, or supplier — who has already won. You have a final court judgment or an arbitral award from outside Türkiye, the debtor has not paid, and the debtor or their assets are in Türkiye. You want to collect.

A foreign judgment or award has no automatic force in Türkiye. You cannot hand it to a Turkish enforcement office and start seizing assets. Before anything can happen, a Turkish court must give the foreign decision legal effect. There are two routes:

  • Recognition (tanıma) — the court accepts the foreign decision as having effect in Türkiye (for example, to rely on a finding or status). It does not, by itself, create a power to seize assets.
  • Enforcement (tenfiz) — the court turns the foreign decision into something you can execute in Türkiye, so you can then pursue the debtor's assets.

If your aim is to collect money, you generally need tenfiz, not just tanıma.

The route depends on what you are holding.

Foreign court judgments are handled under MÖHUK (Law No. 5718), broadly in articles ~50-59. You file a tenfiz case at the competent Turkish court. The court checks a defined set of conditions in MÖHUK 54 — including that the judgment is final, that there is reciprocity (by treaty (anlaşma), statute, or de facto practice) between Türkiye and the country of origin, that the defendant's defence rights were respected, and that the result does not breach Turkish public policy (kamu düzeni). It does not re-try the dispute.

Foreign arbitral awards are handled under MÖHUK arts ~60-63 and, where it applies, the 1958 New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards, to which Türkiye is a party (subject to its commercial and reciprocity reservations). The grounds a court may refuse on are limited and largely mirror Article V of the Convention (for example, an invalid arbitration agreement, lack of proper notice, the tribunal exceeding its mandate, or a public-policy conflict).

The person liable is the debtor named in your judgment or award. Enforcement reaches the assets of that debtor in Türkiye.

Reciprocity is the first gate for judgments. Some countries do not satisfy MÖHUK 54 reciprocity with Türkiye. If yours is one of them, a court judgment may not be enforceable here — which is why we check this at intake before doing anything else. The position is framed differently for arbitral awards.

What you can recover or achieve

A successful tenfiz decision makes your foreign judgment or award executable in Türkiye. With it, you can open Turkish enforcement proceedings (icra takibi) and pursue the debtor's assets here — for example by attaching (haciz) bank accounts, receivables, vehicles, or real estate, within the limits Turkish enforcement law allows.

What the decision covers is the sum and relief set out in your foreign judgment or award — the principal, plus interest and costs as that decision provides. A Turkish court applying tenfiz does not increase or reduce the underlying claim; it gives effect to what you already hold (subject to the conditions above). What is actually collected then depends on the debtor's assets and the enforcement process — something no lawyer can promise in advance.

A judgment travels only with its paperwork

A judgment travels only with its paperwork.Certified copies, finality confirmation, apostille and sworn translation are what make a foreign decision usable in Türkiye.

How long you have

Two different clocks matter, and both should be checked against your exact facts.

First, your underlying judgment or award is itself subject to a time limit for being enforced — generally measured from when it became final. Foreign judgments that are stale under their own law may face difficulty here. Second, once you obtain a Turkish enforcement title, Turkish enforcement law applies its own periods to acting on it.

As a general guide, Turkish practice often treats money judgments as carrying a ten-year enforcement period, but the correct period and start date depend on the type of decision, the country of origin, and the facts. Treat any number you read online as a starting point to be verified, not a settled rule for your case.

Do not wait to check this. Limitation and finality questions can decide whether a case is worth bringing at all. The sooner the dates are reviewed, the more options you keep.
Reviewing assets ahead of enforcement.
Enforcement follows the assets — so they are traced first.

How it works when you are abroad

You do not need to travel to Türkiye to bring a recognition or enforcement case. It can generally be run remotely once the paperwork is in order.

Typically you will need to grant a power of attorney (vekaletname) authorising a Turkish lawyer to act for you. For use in Türkiye, foreign documents — your judgment or award, and supporting papers — usually need to be apostilled (or legalised, depending on the country) and accompanied by a sworn Turkish translation (yeminli tercüme). Courts will expect properly certified copies of the foreign decision showing it is final or binding.

We tell you which documents are needed for your country at the outset, so you can prepare them once and correctly. Communication is in plain English throughout.

Two sets of legal documents compared side by side.
Recognition makes the judgment count here; enforcement is what collects on it.

How we work and your next step

Restitora is the practice of a licensed Turkish lawyer (avukat). We act as your counsel of record and represent you before the Turkish courts and enforcement offices. We are not a debt-collection agency or a claims buyer — you remain the creditor, and we represent you.

Check Treaty Exemptions & Security Deposit (Teminat)

Use our free interactive tool to verify whether your country has a bilateral treaty waiving the foreign plaintiff security deposit under MÖHUK Article 48.

Open Tenfiz & Deposit Checker →

A typical engagement runs in stages: an intake review of your judgment or award and the reciprocity position; the tenfiz (or tanıma) case; and then, if granted, opening Turkish enforcement proceedings (icra takibi) against the debtor's assets.

Fees are explained clearly at the outset. We typically work on a success-fee basis within the limits Turkish law allows (under Avukatlık Kanunu art. 164, a success fee may not exceed 25% and cannot be a pure share of the asset itself). To start, send us your judgment or award and the basic facts, and we will assess whether enforcement in Türkiye is realistic for your situation.

An honest note

Recognition and enforcement is a structured, document-driven process — but it is not automatic, and the outcome cannot be guaranteed. A debtor can contest the case on the limited grounds the law allows, reciprocity may be missing for some countries, and what is ultimately collected depends on the assets the debtor actually has in Türkiye. We will give you a candid read on whether a case is worth bringing before you commit.

This page is general information about Turkish law. It is not legal advice, and reading it does not create a lawyer-client relationship. Your case turns on its own facts, which we would need to review.

📚 Deep Dive: Read our comprehensive guide on enforcing international arbitral awards (ICC, LCIA, SIAC) under the 1958 New York Convention in Türkiye.

Questions

FAQ
What is the difference between recognition (tanıma) and enforcement (tenfiz)?

Recognition gives a foreign decision legal effect in Türkiye — for example to rely on a finding or status — but does not by itself let you seize assets. Enforcement turns the decision into an executable title so you can pursue the debtor's assets through Turkish enforcement proceedings. To collect money, you generally need enforcement (tenfiz).

Will a Turkish court re-examine my case?

No. Under MÖHUK, the court reviews a defined set of conditions only — such as finality, reciprocity (for judgments), defence rights, and public policy. It does not re-try the underlying dispute or re-assess the merits (no révision au fond).

Does the reciprocity rule apply to arbitral awards too?

The reciprocity requirement in MÖHUK 54 is aimed at foreign court judgments. Foreign arbitral awards are handled under MÖHUK arts ~60-63 and, where it applies, the 1958 New York Convention, where the framework is different. Türkiye applies the Convention subject to a reciprocity reservation (awards made in another contracting state) and a commercial reservation. Whether and how reciprocity is in play for an award depends on the seat and any applicable treaty — something to check on your specific facts.

My country may not have reciprocity with Türkiye. Does that end it?

For a court judgment, a lack of reciprocity under MÖHUK 54 can be a real obstacle, which is why we check it at intake. The position can differ for an arbitral award. The only way to know is to have the country of origin and the type of decision reviewed against the current framework.

Do I have to come to Türkiye?

Usually not. The process can generally be handled remotely once you grant a power of attorney (vekaletname) and provide your judgment or award with the required apostille or legalisation and a sworn Turkish translation.

How long does enforcement take, and what will it cost?

Timing depends on the court, whether the debtor contests, and the assets involved, so it cannot be fixed in advance. Fees are explained clearly at the outset; we typically work on a success-fee basis within the limits Turkish law allows (under Avukatlık Kanunu art. 164 a success fee may not exceed 25% and cannot be a pure share of the asset).

Owed money in Türkiye? Let's look at it.

A reply within a day, and an honest view — in English, no pressure.