How to Enforce a Foreign Arbitral Award in Turkey (2026 Guide)

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Winning an international arbitration is only half the battle. Where the award debtor holds assets in Turkey, the foreign arbitral award must be recognised and enforced by Turkish courts before it can produce binding legal consequences. Without this judicial approval — known as exequatur — the award cannot be executed, regardless of where it was rendered or which institution administered the arbitration.

The Legal Framework

Two primary sources of law govern the enforcement of foreign arbitral awards in Turkey.

The New York Convention (1958)

Turkey ratified the Convention on the Recognition and Enforcement of Foreign Arbitral Awards in 1992, with a reciprocity reservation. This means Turkey will enforce awards rendered in other New York Convention signatory states — a network covering over 170 countries. The Convention establishes a strong presumption in favour of enforcement and limits the grounds on which courts may refuse recognition to those exhaustively listed in Article V.

PILPL — Law No. 5718

For awards from non-signatory states, or where bilateral treaty provisions apply, enforcement is governed by Turkey's Private International Law and Procedural Law (PILPL), specifically Articles 60–62. The PILPL applies a parallel but not identical set of conditions — and in certain respects is more restrictive than the Convention, including an additional requirement of reciprocity between Turkey and the country of origin.

Turkey's New York Convention ratification includes a reciprocity reservation. Awards from non-signatory states must be pursued under the PILPL — which carries additional requirements, including proof of reciprocity. Always verify the applicable legal basis before filing.

The Exequatur Process — Step by Step

Enforcement requires filing an exequatur lawsuit before the competent Turkish courts. There is no shortcut: even awards from major institutions such as the ICC or HKIAC require this process in Turkey. ICSID awards are the exception — discussed below.

Identify the Competent Court

Applications are filed before the Civil Courts of First Instance (Asliye Hukuk Mahkemesi) at the domicile of the award debtor in Turkey — or, if no Turkish domicile exists, at the location of the assets to be attached.

Prepare the Required Documents

The applicant must submit the original or certified copy of the arbitral award, the original or certified copy of the arbitration agreement, and notarised Turkish translations of both documents.

File the Exequatur Petition

The petition sets out the legal basis (New York Convention or PILPL), confirms that the conditions for enforcement are satisfied, and requests the court to issue an enforcement order. The petition must be filed by a Turkish-admitted attorney.

Court Review — No Merits Examination

Turkish courts do not review the merits of the underlying dispute (révision au fond is prohibited). The court examines only whether the conditions for enforcement are met. The award debtor is served and may raise objections based on the enumerated grounds.

Enforcement Order Issued

If the conditions are satisfied and no refusal grounds are established, the court issues an exequatur. The foreign award then has the same legal effect as a domestic Turkish court judgment.

Execution Proceedings

The creditor initiates execution proceedings before the relevant Enforcement Office (İcra Müdürlüğü) to attach and liquidate the debtor's assets in Turkey.

Grounds for Refusal

Under both the New York Convention (Article V) and the PILPL, Turkish courts may only refuse enforcement on specific, exhaustive grounds. No other basis for refusal is available — and the burden of proof on most grounds rests with the party resisting enforcement.

Grounds the debtor must raise — Article V(1)

Invalid arbitration agreementThe agreement is not valid under the applicable law, or the parties lacked capacity at the time of signing.

Due process violationThe debtor was not given proper notice of the proceedings, or was otherwise unable to present their case.

Award exceeds submissionThe award deals with matters outside the scope of the arbitration agreement or the parties' submission.

Irregular tribunal or procedureTribunal composition or procedure was not in accordance with the parties' agreement or the law of the seat.

Award not binding or set asideThe award has not yet become binding on the parties, or has been annulled or suspended at the seat of arbitration.

Grounds the court raises ex officio — Article V(2)

Non-arbitrabilityThe subject matter of the dispute is not capable of settlement by arbitration under Turkish law.

Public policy (ordre public)Recognition or enforcement of the award would be contrary to Turkish public policy. The most frequently invoked ground in Turkish enforcement proceedings.

Turkish courts cannot re-examine whether the tribunal reached the correct legal or factual conclusion. The public policy assessment is limited to whether enforcing the award would be manifestly incompatible with fundamental Turkish legal principles.

Practical Considerations for Creditors

The formal legal framework is only part of the picture. Experienced practitioners managing enforcement in Turkey pay close attention to the following:

Identify and preserve assets early Enforcement is only as valuable as the assets available to attach. Consider a precautionary attachment (ihtiyati haciz) before or alongside the exequatur application if there is any risk the debtor may dissipate assets.
Translation quality is not a formality Turkish courts have rejected enforcement applications due to translation deficiencies. Use a sworn translator certified by the Turkish Ministry of Justice — not a general translation agency.
The arbitration clause determines enforcement prospects A defective arbitration agreement is one of the most common grounds for resisting enforcement. Clauses should clearly specify the institution, seat, language, and governing law — and should be reviewed before the dispute arises, not after.
Monitor set-aside proceedings at the seat If the award debtor has commenced annulment proceedings at the seat of arbitration, Turkish courts may stay the enforcement proceedings pending the outcome. Build this contingency into the overall enforcement timeline.
ICSID awards operate differently For ICSID awards, Turkey's obligations under the ICSID Convention (ratified 1988) provide a separate and more direct enforcement route. ICSID awards are enforceable as of right in all member states without domestic court review of the merits — a significant advantage over other institutional awards.
Engage Turkey-qualified counsel at the outset The exequatur petition must be filed by an attorney admitted to a Turkish bar. Engaging Turkish counsel during the arbitration — rather than only at the post-award stage — allows for more effective coordination and reduces the risk of procedural gaps on enforcement.

The Bottom Line

Turkey's enforcement framework is well-established and, under the New York Convention, generally creditor-friendly. But the exequatur process demands procedural precision, and the grounds for refusal — though limited — are actively tested by debtors in Turkish courts.

The most effective enforcement strategies are built at the outset of the arbitration, not after the award is rendered. Proper arbitration clause drafting, early asset identification, and the involvement of Turkey-qualified counsel are decisions that materially affect what happens after an award is issued.

If you have obtained a foreign arbitral award and need to enforce it in Turkey, the time to act is now.

Need to Enforce a Foreign Award in Turkey?

Özgören Law Firm advises creditors on post-award enforcement strategy in Turkey — from precautionary attachment applications to the conduct of exequatur proceedings before Turkish courts.

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This article is published for informational purposes only and does not constitute legal advice. Enforcement outcomes depend on the specific facts and documents of each case, and the legal framework described herein is subject to change. No party should rely on the general principles described herein without obtaining independent legal counsel. © Özgören Law Firm 2026. All rights reserved.