Enforcing a U.S. judgment in Türkiye: recognition, exequatur and state-by-state reciprocity

A judgment from a U.S. court is not directly enforceable in Türkiye (Turkey). The creditor first needs a decision of a Turkish court granting exequatur (tenfiz). This guide explains what the Turkish court checks, how reciprocity with the issuing U.S. state is shown, which documents to prepare and how assets can be protected in the meantime.

It covers civil and commercial money judgments. Family judgments follow the same statute but raise different issues and are mentioned only where the case law is useful. This guide does not interpret U.S. law; where U.S. law is relevant, evidence of it comes from U.S. counsel or official channels.

Recognition or enforcement: which one you need#

Article 50 of Law No. 5718 on Private International and Procedural Law (MÖHUK, "IPPL") makes enforcement of a foreign civil judgment in Türkiye subject to an exequatur decision of the competent Turkish court. Recognition (tanıma) is narrower: it lets a party rely on the foreign judgment as res judicata or conclusive evidence (IPPL Art. 58).

For a creditor who wants to be paid, enforcement is the relevant route.

The conditions under Articles 50 to 54#

The Turkish court does not retry the case. It checks a closed list of conditions:

1. Civil matter and finality. The judgment must concern a civil case and be final under the law of the issuing state (IPPL Art. 50(1)).
2. Reciprocity. There must be a treaty based on reciprocity, a statutory provision in the issuing state allowing Turkish judgments to be enforced, or de facto practice to that effect (IPPL Art. 54(1)(a)).
3. Jurisdiction. The judgment must not concern a matter within the exclusive jurisdiction of Turkish courts. If the debtor objects, it must also not come from a court that took jurisdiction without any real connection to the dispute or the parties (IPPL Art. 54(1)(b)).
4. Public policy. The judgment must not be clearly contrary to Turkish public policy (IPPL Art. 54(1)(c)). The word "clearly" matters: the test is not whether a Turkish court would have decided differently.
5. Right to be heard. If the debtor objects that it was not properly summoned, not represented, or that judgment was given in its absence contrary to the issuing state's law, enforcement is refused (IPPL Art. 54(1)(ç)).

The debtor may object only on these grounds, or argue that the judgment has been satisfied in whole or in part or that another obstacle to enforcement has arisen (IPPL Art. 55(2)).

The U.S. question: reciprocity state by state#

Türkiye and the United States have no treaty on the enforcement of judgments. In the cases discussed below, the Ministry of Justice reported that no bilateral or multilateral treaty applies. Reciprocity therefore has to be shown through a statutory provision or de facto practice.

The Court of Cassation (Yargıtay) has repeatedly held that this inquiry cannot be made for the United States as a whole. In a case concerning a California judgment for damages, it reversed a dismissal because the lower court had relied on a general Ministry reply. The court held that the trial court should have investigated, for the State of California, whether a statute or de facto practice allows foreign judgments to be enforced, and whether the type of judgment raises a specific obstacle (Court of Cassation, 17th Civil Chamber, 2016). The 2nd Civil Chamber took the same approach for a New Jersey judgment (2016).

What this means in practice:

• The petition should identify the issuing state and explain its rules on enforcing foreign money judgments.
• Evidence usually consists of the state's statute and case law, with a sworn translation. A legal opinion may be obtained through official channels; a 2024 Court of Cassation file records an opinion on Texas law obtained through Türkiye's embassy in Washington.
• The court may write to the Ministry of Justice. A general reply about the United States is not enough on its own, so it helps to file state-specific material from the start.

Service and finality: where files are often lost#

Finality is judged under the law of the issuing state, but the Turkish court will want documents that show it. In a case involving a Nevada judgment against a Turkish resident, the regional court dismissed the exequatur action because the file did not show that the judgment had been served on the defendant through the channels of the 1965 Hague Service Convention or that it had become final. The Court of Cassation upheld that decision by majority, with a dissent arguing that formal finality under the issuing state's law should have been enough (Court of Cassation, 11th Civil Chamber, 2020).

The lesson for a U.S. creditor is practical:

• Serve the Turkish defendant in the U.S. proceedings through the Hague Service Convention channel where it applies, and keep the proof.
• Obtain a court document confirming that the judgment is final and that no appeal is pending.
• Make sure the judgment itself, or an attached document, states the amount, interest and costs clearly enough to be enforced.

Documents to prepare#

The petition must state the parties and their representatives, the issuing court, the date and number of the judgment with a summary, and which part is to be enforced if not all of it (IPPL Art. 52). Copies for each opposing party are attached.

Under IPPL Art. 53, the following documents are attached:

1. The original of the judgment duly certified by the authorities of the issuing state, or a copy certified by the issuing court, with a certified Turkish translation.
2. A document certified by the authorities of the issuing state showing that the judgment is final, with a certified Turkish translation.

In practice, U.S. documents are apostilled and then translated by a sworn translator in Türkiye, with the translation notarized. A power of attorney for Turkish counsel is also needed; see our power of attorney guide for U.S. companies.

Court, procedure and appeals#

Court. The petition is filed with the court of first instance at the debtor's domicile in Türkiye, or its residence; if there is neither, with a court in Ankara, Istanbul or Izmir (IPPL Art. 51). Where the judgment concerns a commercial dispute, the Court of Cassation has held that the commercial court of first instance is competent (19th Civil Chamber, 2018).

Procedure. The petition is served on the debtor with the hearing date, and the case is heard under the simple procedure (IPPL Art. 55(1)). The court may grant exequatur in full or in part, or reject the request. The decision is written under the foreign judgment and signed and sealed by the judge (IPPL Art. 56).

Effect and appeals. A judgment granted exequatur is enforced like a Turkish judgment (IPPL Art. 57(1)). Appeals follow the general rules, and an appeal suspends enforcement (IPPL Art. 57(2)). Under the Code of Civil Procedure (Law No. 6100) ("HMK"), the period for a regional appeal is two weeks from service of the decision (HMK Art. 345) and the period for an appeal to the Court of Cassation is also two weeks (HMK Art. 361).

Security for costs#

A foreign company that sues in a Turkish court may be asked to post security for costs unless reciprocity exempts it (IPPL Art. 48). For U.S. claimants, Turkish courts have reached different results over the years. See our guide on security for costs for U.S. claimants.

Court fees#

Court fees are charged under the Fees Law (Law No. 492). For a judgment awarding a sum of money, the fee is proportional to the amount awarded, and one quarter is paid when the action is filed. The Constitutional Court rejected a challenge to this value-based rule in 2024, noting that the debtor can avoid the case by paying voluntarily and that the fee is ultimately charged to the losing debtor (Constitutional Court, E. 2024/104, K. 2024/173). Because fee rates change, we confirm the current amount when the file is opened.

Securing assets while the action is pending#

Exequatur takes time, and a debtor may move assets in the meantime. A creditor can consider precautionary attachment (ihtiyati haciz) under Article 257 of the Enforcement and Bankruptcy Law (Law No. 2004) ("EBL").

• The Court of Cassation has held that attachment based on a debt established by a foreign judgment or award does not require prior exequatur, because attachment only freezes assets temporarily (6th Civil Chamber, 2014).
• Some regional courts take a stricter view. The Istanbul Regional Court of Appeal refused attachment where the creditor relied only on a foreign judgment not yet recognized and offered no other evidence of the debt (43rd Civil Chamber, 2023).
• Counter-security is generally required, because a foreign judgment is not a Turkish judgment until exequatur is granted (EBL Art. 259).

How long does it take?#

We do not give a fixed timeline. The main factors are:

• how quickly the petition can be served on the debtor,
• whether reciprocity evidence for the issuing state is complete at filing,
• whether the debtor objects and on which grounds,
• the workload of the court, and
• whether the decision is appealed, which suspends enforcement.

Bottom line#

A U.S. money judgment can be enforced in Türkiye, but only through an exequatur action. The decisive issues are usually reciprocity for the specific U.S. state, proof of proper service and finality, and complete certified translations. Preparing state-specific reciprocity evidence and a clean set of documents before filing is the most effective way to avoid delay.

Frequently asked questions

Law stated as at: October 11, 2026. Leyla Başkaya Şentürk is a lawyer (avukat) admitted to the Istanbul Bar Association, Türkiye (Reg. No. 67063). She advises on Turkish law only, is not admitted to practise law in any U.S. jurisdiction and does not advise on U.S. law. Content on this website is general information, not legal advice, and no outcome is promised. Using this website or submitting the contact form does not create an attorney-client relationship.