Recognition and enforcement of foreign judgments
Recognition or enforcement: which do you need?
Select the type of decision and the country where it was issued. The route and required documents are listed.
The court does not re-examine the case; it only checks the legal conditions. No outcome is promised.
Recognition and enforcement of foreign judgments: foreign court decisions in Turkey
Recognition and enforcement of foreign judgments is the route by which a foreign court decision takes effect in Turkey. If only the effect of res judicata and conclusive evidence is needed, for example to register a divorce in the civil registry, recognition is enough. If the decision is to be enforced, such as a maintenance or money claim, enforcement (exequatur) is required. In some cases, foreign divorce decisions can also be registered administratively through the civil registry or a consulate (Law No. 5490, Art. 27/A). The conditions for the court route are set out in Arts. 50–59 of Law No. 5718 (MÖHUK).
The difference between recognition and enforcement of foreign judgments
- Recognition: the decision takes effect as res judicata and conclusive evidence; typical for registering a divorce, parentage or custody in the civil registry (MÖHUK Art. 58).
- Enforcement: the decision becomes enforceable in Turkey; required for maintenance, money claims or delivery orders.
- Reciprocity: required for enforcement (Art. 54/a), not for recognition.
Registering a foreign divorce at the civil registry
Under Art. 27/A of Civil Registration Services Law No. 5490, a final foreign divorce decision that is not clearly contrary to public order can be registered at a civil registry office or Turkish consulate on the joint application of the spouses. If one spouse is a foreigner, the Turkish spouse can apply alone. Only the divorce itself is registered this way; ancillary matters such as maintenance, custody or matrimonial property are not covered and require the court route.
Conditions for recognition and enforcement under MÖHUK
- The decision must be final under the law of the country where it was issued.
- The matter must not fall within the exclusive jurisdiction of Turkish courts.
- The decision must not be clearly contrary to Turkish public order.
- The defendant must have been duly summoned and able to exercise the right of defence.
- For enforcement only: de facto or legal reciprocity with the country of the decision.
The Turkish court does not re-examine the merits of the case (prohibition of révision au fond); it only checks these conditions.
How does a recognition or enforcement case proceed?
Choose the route
Administrative registration, recognition case or enforcement case, depending on the type of decision and the goal.
Complete the documents
Certificate of finality, proof of service, apostille and translation.
File the case
Family courts hear decisions on personal status. The competent court is that of the defendant's domicile in Turkey, otherwise their residence, otherwise the courts of Ankara, Istanbul or Izmir (MÖHUK Art. 51).
Service on the other party
Service abroad prolongs the process.
Decision and registration / enforcement
The final decision is entered in the civil registry, or enforcement proceedings are started.
The case can be conducted without travelling to Turkey, with a power of attorney given abroad.
Documents for recognition and enforcement
- Original or certified copy of the foreign court decision
- Annotation or document showing the decision is final
- Proof that the defendant was duly served
- Apostille, or the foreign ministry and consular legalisation chain
- Sworn Turkish translation of all documents
- Power of attorney if a lawyer conducts the case
Missing finality and service documents are among the main causes of delay or rejection.
Questions about recognition and enforcement of foreign judgments
Does the Turkish court re-examine the decision?
No. The court only checks the legal conditions for recognition or enforcement.
Can a divorce obtained abroad be registered without going to court?
If the conditions of Law No. 5490, Art. 27/A are met, it can be registered through a civil registry office or a Turkish consulate; otherwise a recognition case is needed.
Do I need to come to Turkey?
No. The case can be conducted by a lawyer with a power of attorney.
How long does the case take?
It depends on service on the other party and the court's workload; administrative registration is usually quicker.
Can a foreign maintenance order be enforced in Turkey?
Yes, after an enforcement decision is obtained; reciprocity is examined for enforcement.
This guide is based on the official legislation of the Republic of Türkiye and was last updated on .
This page provides general information and is not a substitute for legal advice on a specific case. No particular outcome of any application or proceeding is promised.
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