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A judgment given abroad has no automatic effect in Türkiye. To be registered with the civil registry, relied on as final, or enforced against assets in Türkiye, it must be recognised (tanıma) or enforced (tenfiz) by a Turkish court under Articles 50–59 of the Turkish Code on Private International and Procedural Law.
At a glance
- Recognition
- Gives the judgment the effect of a final decision
- Enforcement
- Allows the judgment to be executed in Türkiye
- Reciprocity
- Required for enforcement, not for recognition
- Court
- Civil court of first instance; family court for family matters
Conditions
- The judgment must be final under the law of the country where it was given.
- For enforcement, there must be reciprocity — by treaty, by law or in practice — between Türkiye and that country.
- The subject matter must not fall within the exclusive jurisdiction of Turkish courts, and the foreign court must not have assumed jurisdiction without a genuine connection when the defendant objected.
- The judgment must not be manifestly contrary to Turkish public policy.
- The defendant must have been duly summoned and represented, and must not have objected on that ground before the Turkish court.
Documents
The application must include the original or a certified copy of the judgment and a certificate showing that it is final, both apostilled (or legalised) and translated into Turkish by a sworn translator. The applicant provides the Turkish identity details of any Turkish party.
Since 2018, divorce decisions given abroad can in some cases be recorded directly by civil registry offices or consulates without a court case — mainly consensual decisions where both spouses apply together. Where this route is not available, a recognition action is filed before the family court.
Procedure
The case is a simplified proceeding: the court does not re-examine the merits of the foreign judgment, only whether the conditions are met. The other party is notified and may raise the limited defences allowed by law — that the judgment has been satisfied or that an obstacle has arisen. Where the other party lives abroad, service through international channels usually takes the most time.
After the decision
Once recognised, a foreign divorce is registered in the Turkish civil registry and the parties may remarry in Türkiye. An enforcement decision allows the creditor to start enforcement proceedings against assets in Türkiye; see our debt collection guide.
What about foreign arbitral awards?
Arbitral awards are enforced under the New York Convention, to which Türkiye is a party, before the civil courts.
How long does recognition take?
If the other party is served quickly and documents are complete, a decision may be given within a few months; service abroad can extend this considerably.
This article is for general information only and does not constitute legal advice. Time limits, rates and thresholds may change with new legislation; please have your specific situation assessed by a lawyer before taking action.
Prepared by
Candan Law & Consultancy
An Ankara-based law firm practising since 1997, representing individuals, companies and public-sector contractors in Turkish, English and French.
