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 is the easy part. Turkish courts have accepted reciprocity with Germany for decades. What actually sinks cases is 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. If you fix those three things before you file, you are in good shape. If you ignore them, you will spend two years and lose.

Reciprocity with Germany: what the 1930 convention actually covers

People send us the Turkish-German Convention on Legal Relations, signed in 1929 and in force from 1930, 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. 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. Germany satisfies the second and the third. German law provides for recognition of foreign judgments and for a declaration of enforceability under the Zivilprozessordnung, and German courts in fact declare Turkish judgments enforceable. Turkish courts treat German reciprocity as established. You should still plead it properly, with the German provisions cited, because it is a condition the court examines on its own motion.

The 1930 convention still earns its keep in two practical ways. It exempts German claimants from the security for costs that MÖHUK Article 48 otherwise requires from foreign parties, 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, and Turkish judges apply it strictly. 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). Getting it at a Turkish consulate in Germany is faster and cheaper than a German notarial power with apostille and translation.

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. 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. 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

Public policy objections are raised in almost every defended case and succeed in few. Punitive or multiplied damages are a genuine risk area. The absence of reasoning is not. German default judgments are often issued in abbreviated form with no reasons, and debtors used to argue that this breached the Turkish constitutional requirement that judgments be reasoned. In a 2012 unification-of-judgments ruling, the Court of Cassation settled the point: a foreign judgment is not contrary to Turkish public policy merely because it contains no reasoning. If you hold a Versäumnisurteil, that ruling is your answer.

The procedure and the real timeline

You file a petition in the competent court with the documents above and pay the court fee. The debtor is summoned and served. The case runs under the simple trial procedure, which in practice means a few short hearings, mostly about documents and translations rather than witnesses.

Expect eight to eighteen months at first instance in Istanbul for a defended case. Add roughly a year, sometimes more, if the losing side appeals to the regional court of appeal (istinaf), and that appeal has to be lodged within two weeks of service of the judgment. An appeal suspends execution, so a determined debtor buys time simply by filing one. A further appeal to the Court of Cassation is possible in cases above the statutory threshold, again on a two-week deadline.

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 can be claimed in euro, or in Turkish lira at the rate applying on the payment date, and the difference is not trivial. Second, timing. Enforcement based on a judgment time-bars ten years after the last enforcement step, so a German title you sat on for years may already be a problem.

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. A default judgment built on that foundation is the single most common German title we decline to take on.

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 the Population Services Law No. 5490 has also allowed both former spouses to register a foreign divorce directly at a Turkish civil registry office or consulate, without a court case, if they apply together. 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 Hague maintenance conventions, which give you a Central Authority route through the Turkish Ministry of Justice. It is slower in correspondence but far cheaper than a private enforcement action, and for a modest monthly sum it is usually the better choice.

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. Within a few days 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.