How to Enforce a German Judgment in Turkey: 2026 Guide

A German judgment has no force in Turkey on its own. You cannot hand a Landgericht judgment to a Turkish enforcement office and start freezing a bank account in Istanbul. You have to win a separate case first: an enforcement action (tenfiz), heard by a Turkish court, which produces a Turkish judgment. Only that Turkish judgment can be executed. The rules are in the Act on Private International Law and Procedural Law, Law No. 5718 (MÖHUK), Articles 50 to 59.

The reciprocity question that worries most German creditors has a statutory answer. MÖHUK Article 54(a) does not require a treaty: a provision of German law allowing Turkish judgments to be enforced, or an actual practice of enforcing them, is enough. The points to watch are narrower and more mundane: the German judgment is not yet final, the Turkish defendant was never properly served, or the title is not a court judgment at all. Fix those three things before you file. Ignore them and the case can fail on paperwork, whatever the merits of the German judgment.

Reciprocity with Germany: what the 1929 convention actually covers

People send us the Turkish-German Convention on Legal Relations, signed in Ankara on 28 May 1929 and in force since 18 November 1931, as proof that German judgments are enforceable in Turkey. It is the wrong document for that purpose. That convention is a judicial assistance treaty. It governs service of documents between the two countries, letters rogatory for taking evidence, legal aid, and exemption from the security for costs that foreign claimants would otherwise post. Apart from a narrow rule on costs orders against a claimant who was exempt from security (Articles 3 and 4), it contains nothing about declaring a German judgment enforceable in Turkey.

Reciprocity comes from somewhere else. MÖHUK Article 54 accepts three alternative sources: a treaty, a provision of the foreign state's own law that allows Turkish judgments to be enforced there, or an actual practice of enforcing them. For Germany the argument runs through the second and the third. German law provides for recognition of foreign judgments and for a declaration of enforceability under the Zivilprozessordnung, and a creditor who can document German decisions giving effect to Turkish judgments can add the third. Plead it properly, with the German provisions cited: reciprocity is a condition of Article 54 that the court examines in every file, whether or not the debtor raises it.

The 1929 convention still earns its keep in two practical ways. It exempts German nationals domiciled in either state from the security for costs (Article 2) that MÖHUK Article 48 otherwise requires from foreign claimants, which saves a real deposit. And it, together with the 1965 Hague Service Convention to which both countries belong, sets the channel through which your Turkish case papers reach a defendant in Germany. Note one detail that matters later: both Turkey and Germany have objected to Article 10 of the Hague Service Convention, so service by post between the two countries is not valid service.

The German documents a Turkish court needs

MÖHUK Article 53 lists what goes with the petition. You need a certified copy of the judgment issued by the German court's registry, and a separate written confirmation that the judgment has become final. Both need an apostille, because Turkey and Germany are both parties to the 1961 Hague Apostille Convention, and both need a sworn Turkish translation that is then notarised.

The confusion we see most often is between enforceability and finality. A German judgment can be enforceable in Germany while an appeal is still possible, and the Vollstreckungsklausel reflects that. Turkey does not care about German enforceability. It cares whether the judgment is final under German law. Ask the registry of the court that decided the case for the Rechtskraftvermerk, and do it before you instruct anyone in Turkey.

You will also need a Turkish-form power of attorney (vekaletname). A power signed at a Turkish consulate in Germany is drawn up in Turkish and avoids the apostille and translation steps that a German notarial power needs.

What the Turkish court checks, and what it refuses to reopen

MÖHUK Article 54 sets out the conditions, and the list is closed. Reciprocity. The matter must not fall within the exclusive jurisdiction of Turkish courts and, if the defendant objects, the German court must not have taken jurisdiction without a genuine connection to the dispute or the parties. The judgment must not be manifestly contrary to Turkish public policy (kamu düzeni). And the defendant may object that they were not duly summoned or represented before the German court, or that a default judgment was given in breach of German law.

Exclusive jurisdiction is the trap for property cases. Rights in rem over immovable property in Turkey belong to Turkish courts alone: HMK Article 12 makes the court where the property lies exclusively competent. A German judgment ordering transfer of title to an apartment in Istanbul will not be enforced, however clearly reasoned it is. Those disputes have to be brought here, and our real estate practice handles them as Turkish title actions rather than as enforcement applications.

What the court will not do is re-examine the merits. There is no review of the substance. If the German court miscalculated your interest, or applied the wrong contract term, or dismissed half your claim, the Turkish court will not fix any of it. That cuts both ways: your debtor cannot re-argue the case in Turkey either, and defence submissions that amount to a rehearing get rejected.

Public policy is narrower than debtors hope

The statute sets a high bar. Article 54(c) refuses enforcement only where the judgment is manifestly contrary to public policy (kamu düzenine açıkça aykırı), and Article 55(2) confines the debtor's objections to three things: that the enforcement conditions are missing, that the judgment has been performed in whole or in part, or that something has since arisen that prevents its performance. An award of punitive or multiplied damages invites a public-policy objection. A missing statement of reasons is a separate question. German default judgments may be issued in abbreviated form with no reasons, and debtors argue that this offends Article 141 of the Turkish Constitution, under which every decision of every court is to be written with its reasons. The enforcement provisions do not list the absence of reasons as a ground of refusal; whether an unreasoned foreign judgment is manifestly contrary to public policy is a matter for the court's assessment of the file. If you hold a Versäumnisurteil, file it with the claim documents and the service record, so the court can see what was claimed, how the defendant was summoned and what was decided.

The procedure and the statutory stages

You file a petition in the competent court with the documents above and pay the court fee. The debtor is summoned and served. Under MÖHUK Article 55 the petition is served on the debtor together with the hearing date, and the request is examined under the simple trial procedure, in which the debtor has two weeks from service of the petition to answer (HMK Article 317). Because the debtor's objections are confined to the enforcement conditions, the file turns on documents: the judgment, its finality, service abroad and the translations.

Turkish law sets no time limit for the court to decide a defended case, so any fixed figure would be a guess. The statute fixes the deadlines that fall on the parties instead. The losing side has two weeks from service of the judgment to appeal to the regional court of appeal (istinaf) (HMK Article 345). Under MÖHUK Article 57 an appeal suspends execution, so a determined debtor buys time simply by filing one. A further appeal on points of law (temyiz) is open only above the value threshold in HMK Article 362.

Once the enforcement judgment is final, you go to the enforcement office (icra müdürlüğü) under the Enforcement and Bankruptcy Law No. 2004 and proceed exactly as if you held a Turkish judgment: attachment of bank accounts, salary, vehicles and registered property. Two points to decide in advance. First, currency. Under the Turkish Code of Obligations (TBK) Law No. 6098 Article 99, a debt expressed in euro may be paid in Turkish lira at the rate on the payment date unless the contract requires payment in euro itself, and if it is not paid when due the creditor can ask for payment in euro, or in lira at the rate on either the due date or the actual payment date; the difference is not trivial. Second, timing. Once enforcement has started, an enforcement based on a judgment is time-barred ten years after the last step taken in the file (İİK Article 39), so do not let the file sit idle.

Where German titles fail

The case you have to win in Turkey is almost never about the merits of your German judgment. It is about whether the paperwork proves finality and whether the defendant was properly served. Prepare those two points as though they were the whole case, because they are.

The judgment is only provisionally enforceable

A judgment declared vorläufig vollstreckbar is enforceable in Germany but not final. Turkey requires finality. Filing before the Rechtskraft is a wasted case. Wait for the appeal period to run or for the appeal to be decided.

An order for payment from the Mahnverfahren

A Vollstreckungsbescheid is a court title and it can carry a finality endorsement, so it is arguable. It is also contested, because the debtor was never heard. The real fight is the defence-rights ground in Article 54: if your Turkish-resident debtor never received the Mahnbescheid through a valid channel, the objection is a strong one and you may well lose. Where the debtor is a Turkish company with assets, we often advise suing on the underlying contract in Turkey instead, and our litigation team will compare the two routes on time and cost before you commit.

Notarial deeds and other non-court titles

A vollstreckbare Urkunde executed before a German notary is enforceable in Germany and worth nothing under MÖHUK Article 50, which applies to judgments of foreign courts. We would tell you not to file. Sue in Turkey on the underlying obligation.

Service by public notice or by post

If the German court served your defendant by öffentliche Zustellung while a Turkish address was known, or if service went by post into Turkey, the judgment is exposed. Postal service between Germany and Turkey is not valid service under the Hague Service Convention, because both states objected to it.

Interim measures

An einstweilige Verfügung or an Arrest is not a final judgment and cannot be enforced here. If you need assets frozen in Turkey while the German case runs, apply for a Turkish interim attachment (ihtiyati haciz) as a separate Turkish application.

Divorce, maintenance and arbitral awards take different routes

Not everything goes through a full enforcement case. A German divorce decree usually needs recognition rather than enforcement, and recognition does not require reciprocity at all, because MÖHUK Article 58 disapplies that condition. Since 2017 Article 27/A of the Population Services Law No. 5490 has also allowed a foreign divorce to be registered without a court case, at the Turkish mission in the country where the decree was given or at a population directorate designated by the Ministry of the Interior, where both former spouses apply together or, where one of them has died or is a foreign national, where the Turkish citizen applies alone. The practical steps are set out in our guide to the recognition of foreign divorce decrees in Turkey.

Child maintenance decisions have their own channel. Turkey and Germany are both bound by the 2007 Hague Child Support Convention (Turkey since 1 February 2017, Germany through the European Union), which gives you a Central Authority route through the Turkish Ministry of Justice as an alternative to a private enforcement action.

If what you hold is an arbitral award rather than a judgment, the regime is the 1958 New York Convention, with different grounds and a different court file: see enforcing foreign arbitral awards in Turkey. If you hold an English judgment, the reciprocity analysis is not the same as Germany's and is worth reading separately in our guide to enforcing an English court judgment in Turkey.

What to send us

Send a scan of the German judgment as issued by the registry, the Rechtskraftvermerk if you already have one, and the service file if the defendant did not appear. Add the debtor's full name as written in Turkish records, their Turkish identity or tax number if you know it, their last known address in Turkey, and anything you know about their assets here. You do not need translations yet. Our recognition and enforcement team will tell you whether the title is enforceable as it stands, what is still missing from Germany, a realistic cost and timetable, and whether the debtor has anything in Turkey worth pursuing. If the honest answer is that the case is not worth filing, that is what you will be told.

This guide is general information on Turkish law, not legal advice on your own matter. Rules and practice change; check the position before you act.