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Enforcement and Bankruptcy Law

Enforcing a UAE Judgment in Turkey: Conditions and Documents

Published:Last updated:Legislation last checked:By Att. Halit Süha Bahçeci

Enforcing a UAE judgment in Turkey requires a Turkish court’s enforcement authorisation, known as tenfiz. The foreign civil judgment must be final under the law of the state where it was issued. An authenticated Dubai judgment is therefore a document for the application, rather than an immediately executable Turkish enforcement title (5718 sayılı Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun m.50).

This guide concerns civil money judgments, including commercial debt disputes. If there is no judgment yet, the debt collection guide explains the separate payment-claim routes. Keep the issuing court, the debtor’s identity and the location of assets distinct from the creditor’s place of residence.

1. Enforcing a UAE Judgment in Turkey: Recognition or Enforcement?

Enforcing a UAE judgment in Turkey and recognising it serve different purposes. Recognition, tanıma, concerns the judgment’s binding or conclusive evidential effect. Enforcement authorisation permits execution. The recognition provision dispenses with the reciprocity condition applicable to enforcement; recognition alone does not authorise collection against Turkish assets (5718 sayılı Kanun m.50, m.58).

A petition should identify the effect actually needed. For a money creditor seeking payment, a request limited to recognition leaves the execution question unresolved. The judgment’s binding or conclusive evidential effect runs from the time it becomes final in the issuing state, which makes the finality date relevant to the effect claimed (5718 sayılı Kanun m.59). For an Arabic explanation of the same distinctions, see تنفيذ حكم أجنبي في تركيا.

2. Enforcing a UAE Judgment in Turkey: Is Reciprocity Established?

Enforcing a UAE judgment in Turkey requires reciprocity under one of three statutory routes: an agreement based on reciprocity, a foreign statutory provision enabling enforcement of Turkish judgments, or actual practice. A treaty is one route, rather than the sole route. This guide does not assume that the condition is met for every UAE instrument or issuing court (5718 sayılı Kanun m.54/1-a).

The practical file should identify the issuing state and court, the instrument’s legal character and the material relied on to establish reciprocity. A creditor’s Dubai address does not establish how Turkish judgments are treated in the issuing state. Nor does a document’s authentication establish reciprocity: authentication addresses the document, while reciprocity addresses enforcement.

A separate provision requires foreign individuals and legal entities bringing proceedings or pursuing enforcement to provide security for procedural costs and the opposing party’s loss, with an exemption based on reciprocity. Check this issue independently; the statute gives no universal deposit percentage (5718 sayılı Kanun m.48).

3. Enforcing a UAE Judgment in Turkey: Documents and Finality

Enforcing a UAE judgment in Turkey requires both the judgment and proof that it is final. Article 53 specifies a duly certified original or a copy certified by the issuing judicial authority, a certified translation, and an authenticated document or writing showing finality with its certified translation. A copy of the judgment without finality evidence does not complete this statutory document set (5718 sayılı Kanun m.53).

Prepare the file in the following order:

  1. Identify the judgment and any part for which enforcement is requested. The petition states the foreign court, judgment date and number, a summary and the full or partial relief sought (5718 sayılı Kanun m.52).
  2. Obtain the certified judgment and finality evidence required by Article 53.
  3. Arrange the required Turkish translations. Foreign public documents also raise the certification rule and any applicable treaty exception (6100 sayılı Hukuk Muhakemeleri Kanunu m.223–224).
  4. Prepare service and representation records relevant to any objection under Article 54.

The HCCH Apostille Convention status table, checked on 2 October 2026, does not list the UAE as a contracting party. Do not assume that an apostille route is available merely because Turkey participates. Identify the correct authentication route for the particular document and any other applicable agreement.

Where representation is arranged from Dubai, the power of attorney guide addresses the separate authority document. The Turkish Consulate General in Dubai publishes its consular and notarial contact arrangements in an undated notice, checked on 2 October 2026. A power of attorney does not replace the judgment or its finality evidence (Hukuk Muhakemeleri Kanunu m.76; 5718 sayılı Kanun m.53).

When a lawyer represents the applicant, the file must contain the notarised original authority document or the copy certified as corresponding to it by the lawyer. The powers needed for the intended steps must also be checked: settlement, waiver of proceedings or remedies, acceptance of the opposing claim and release of the opposing party require express authority. A document authorising representation should therefore be read against the acts actually planned (6100 sayılı Hukuk Muhakemeleri Kanunu m.74; m.76).

3.1. Enforcing a UAE Judgment in Turkey: What Does Each Document Prove?

Enforcing a UAE judgment in Turkey requires distinguishing the statutory attachments from material addressing a contested condition. The judgment and finality evidence, with their certified translations, are the attachments specified in Article 53. The checks below help organise the rest of the file; they do not establish that every listed record is mandatory in every case (5718 sayılı Kanun m.53; m.54; m.55/2).

File itemQuestion it answersIssue it does not resolve by itself
Certified judgment and translationWhich court ruled, against whom and on which obligation?Whether the judgment is final under the issuing state’s law (5718 sayılı Kanun m.50; m.53)
Authenticated finality evidence and translationHas the judgment become final?Whether summons and representation satisfied the relevant conditions (5718 sayılı Kanun m.53; m.54/1-ç)
Summons and representation recordsWhat happened when the debtor was called to and represented in the foreign proceedings?Whether reciprocity is established (5718 sayılı Kanun m.54/1-a; m.54/1-ç)
Material supporting reciprocityWhich agreement, statutory provision or actual practice is relied on?Whether the judgment documents have been authenticated (5718 sayılı Kanun m.53; m.54/1-a)
Payment or satisfaction recordsHas the obligation already been performed in full or in part?Whether the unpaid part meets the other enforcement conditions (5718 sayılı Kanun m.55/2)

Compare the debtor’s name in the judgment with the person against whom the petition is directed. If only part of the obligation remains at issue, identify the relief requested and the payment record separately, rather than treating the original amount as proof that the whole debt remains unpaid (5718 sayılı Kanun m.52/1-a; m.52/1-c; m.55/2).

4. Enforcing a UAE Judgment in Turkey: Jurisdiction and Notice

Enforcing a UAE judgment in Turkey is subject to the conditions concerning exclusive Turkish jurisdiction, the foreign court’s genuine connection with the dispute or parties, manifest incompatibility with public policy, and the specified notice and representation defects. The objection requirements within the statute matter; they should not be omitted from a checklist (5718 sayılı Kanun m.54).

The lack of a genuine connection is assessed under the statutory condition requiring the defendant’s objection. The notice provision similarly concerns improper summons, missing representation or an absent judgment contrary to the issuing state’s procedural law, together with an objection on that basis. A judgment given in someone’s absence is not automatically the same as a judgment given without proper notice (5718 sayılı Kanun m.54/1-b, m.54/1-ç).

The statute assigns enforcement applications to first-instance courts. Territorial venue follows the person against whom enforcement is requested: domicile in Turkey, then residence; if neither exists, one of Ankara, Istanbul or Izmir may be selected. The creditor’s preferred asset location is not the entire statutory venue test (5718 sayılı Kanun m.51).

The type of first-instance court is a separate question from its geographical venue. Article 51 uses the term asliye mahkemesi; the provisions governing commercial disputes must be considered when identifying the relevant court. The Commercial Code addresses which disputes are commercial and allocates commercial cases to the commercial court unless a contrary rule applies. The creditor’s Dubai address alone answers neither question (5718 sayılı Kanun m.51/1; 6102 sayılı Türk Ticaret Kanunu m.4–5).

4.1. Enforcing a UAE Judgment in Turkey: Claims Concerning Turkish Property

Enforcing a UAE judgment in Turkey requires examining whether the subject falls within exclusive Turkish jurisdiction. Claims concerning rights in rem over immovable property, changes in those rights, possession or retention are subject to the statutory exclusive venue rule for the place where the property is situated. A judgment concerning ownership of Turkish property must therefore be distinguished from a money judgment arising from a property-related contract (5718 sayılı Kanun m.54/1-b; 6100 sayılı Hukuk Muhakemeleri Kanunu m.12/1).

Identify the relief written in the judgment: transfer or determination of a property right, or payment of a stated sum. The existence of a property transaction does not, by itself, describe the relief granted. The buying property in Turkey guide explains the separate title and contract questions; the enforcement file must still address the actual judgment and statutory condition.

5. Enforcing a UAE Judgment in Turkey: Decision and Recovery

Enforcing a UAE judgment in Turkey can result in full authorisation, partial authorisation or refusal. The petition and hearing date are served on the opposing party, and the statute provides the simplified procedure and limits for objections. These include the statutory conditions, satisfaction of the judgment or an event preventing its execution (5718 sayılı Kanun m.55–56).

Enforcing a UAE judgment in Turkey starts with an application by a person having a legal interest. Prepare the application and subsequent recovery in this order:

  1. Identify the final civil judgment, the legal interest and the full or partial obligation for which enforcement is sought (5718 sayılı Kanun m.50; m.52).
  2. Assemble the certified judgment, finality evidence and their certified translations, then examine reciprocity, exclusive jurisdiction, public policy and the notice or representation issues (5718 sayılı Kanun m.53–54).
  3. Submit the petition and the required copies to the appropriate court. The petition and hearing date are served on the opposing party, and the application is examined under the simplified procedure (5718 sayılı Kanun m.51–52; m.55/1).
  4. Address objections concerning the enforcement conditions, full or partial satisfaction, or an event preventing execution. Keep subsequent payment records with the judgment so the remaining requested obligation can be identified (5718 sayılı Kanun m.55/2).
  5. After full or partial authorisation, pursue execution of the authorised judgment under the rules for Turkish judgments and check the position of any cassation appeal (5718 sayılı Kanun m.56–57).

An authorised judgment is executed like a Turkish judgment. Article 57 also states that an appeal to the court of cassation suspends execution. The authorisation decision and the availability of recoverable assets remain separate questions (5718 sayılı Kanun m.57).

If the debtor is a company, examine its status and the company liquidation procedure. A judgment against the company does not itself create a judgment against its shareholder or director. The director liability guide explains the separate basis needed for a personal claim.

Those with the required access credentials may follow available case services through the UYAP Citizen Portal or use the Ministry of Justice’s enforcement-file enquiry service on e-Devlet, which requires identity verification. These are follow-up channels; using them does not replace the enforcement petition, its attachments or the court’s authorisation.

5.1. Enforcing a UAE Judgment in Turkey: Can I Apply Without a Lawyer?

Enforcing a UAE judgment in Turkey may be pursued personally by a person with capacity to litigate or through an appointed representative. That option does not remove the requirements concerning finality, certified attachments, the appropriate court, reciprocity and any notice objection. Legal assistance may be obtained when preparing the file and coordinating the foreign documents with the Turkish proceedings (6100 sayılı Hukuk Muhakemeleri Kanunu m.71/1; 5718 sayılı Kanun m.51; m.53–54).

5.2. Enforcing a UAE Judgment in Turkey: Arbitral Awards

Enforcing a UAE judgment in Turkey should first establish whether the instrument is a judicial judgment or an arbitral award. Foreign arbitral awards have a separate statutory route and document requirements, including the arbitration agreement and award. Applicable treaty rules require their own examination; the court-judgment reciprocity checklist should not simply be copied into an arbitration file (5718 sayılı Kanun m.60–62).

The statutory arbitration route addresses an award that is final and enforceable, or binding on the parties. Its petition includes the arbitration agreement or clause, the award and the duly certified translations in the forms specified by Article 61. Venue first follows the place agreed in writing by the parties; without that agreement it follows the respondent’s Turkish domicile, then residence, then the location of assets capable of execution. That final asset-location step differs from the Ankara, Istanbul or Izmir alternatives in the court-judgment route (5718 sayılı Kanun m.60–61; m.51/2).

Keep the arbitration agreement and records of appointment, notice and opportunity to present a defence with the award. Article 62 contains separate refusal grounds and allocates the burden of proving the matters in subparagraphs ç–h to the party against whom enforcement is sought. The label “Dubai decision” is therefore insufficient to choose between the judicial-judgment and arbitral-award applications (5718 sayılı Kanun m.62).

Frequently Asked Questions

Can a Dubai judgment be executed directly in Turkey?

A foreign civil judgment must be final under the issuing state’s law and receive Turkish enforcement authorisation before execution in Turkey. A UAE judgment does not become executable merely because it has been translated or authenticated. The court examines the statutory enforcement conditions (5718 sayılı Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun m.50, m.54).

Is a reciprocity treaty compulsory?

Reciprocity can rest on an agreement, a foreign statutory provision allowing enforcement of Turkish judgments, or actual practice. A missing treaty therefore does not by itself settle the question. The relevant position for the issuing state must be established rather than assumed from the creditor’s UAE address (5718 sayılı Kanun m.54/1-a).

Which documents accompany the enforcement petition?

The petition needs a duly certified judgment original or a copy certified by the issuing court, together with a certified translation. It also needs an authenticated document or writing demonstrating finality, with its certified translation. Evidence of the amount alone does not replace these requirements (5718 sayılı Kanun m.53).

Can a judgment given in the debtor’s absence be enforced?

Absence alone does not answer the question. The statute addresses improper summons or representation, or an absent judgment contrary to the issuing state’s procedural law, together with the debtor’s objection on that basis in Turkey. Examine service and representation records alongside the judgment (5718 sayılı Kanun m.54/1-ç).

Does recognition allow collection of the judgment debt?

Recognition concerns a foreign judgment’s binding or conclusive evidential effect. Execution against assets requires enforcement authorisation. Recognition uses the enforcement conditions except reciprocity, so the two applications should be chosen according to the effect sought rather than treated as interchangeable procedures (5718 sayılı Kanun m.50, m.58).

Does a Dubai arbitral award follow the same procedure?

A foreign arbitral award is addressed by separate statutory provisions. The rule covers an award that is final and enforceable, or binding on the parties, and specifies its own application documents and refusal grounds. Identify whether the instrument is a court judgment or an arbitral award before selecting the procedure (5718 sayılı Kanun m.60–62).

Can I request enforcement of only part of the UAE judgment?

Yes. The petition must identify the part for which enforcement is requested, and the Turkish court may authorise enforcement in full or in part, or refuse the application. Identify the requested obligation and retain evidence of any payment already made; satisfaction of the judgment is a statutory objection (5718 sayılı Kanun m.52/1-c; m.55/2; m.56).

Can I apply to enforce a UAE judgment without a lawyer?

A person with capacity to litigate may bring and conduct proceedings personally or through a representative. The file still needs the certified judgment, finality evidence and translations, and the appropriate court and enforcement conditions must be checked. Legal assistance may be obtained to prepare those documents and distinguish objections from execution (6100 sayılı Hukuk Muhakemeleri Kanunu m.71/1; 5718 sayılı Kanun m.51, m.53–54).

Legal Sources

The legal statements in this guide rely mainly on the Turkish legislation below. The relevant articles are also cited in the text.

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Att. Halit Süha Bahçeci

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At Bahceci Law Firm, he provides legal advice and handles litigation in criminal, real estate, employment, family, administrative, commercial and immigration law. His work also includes drafting contracts, handling administrative applications and representing clients in legal disputes.

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