Recognition and enforcement of UK judgments in Turkey (tanıma / tenfiz)

Recognition and enforcement are two different orders

A judgment given by a court in England, Wales, Scotland or Northern Ireland has no effect in Türkiye until a Turkish court says so. Law 5718 on Private International and Procedural Law (Milletlerarası Özel Hukuk ve Usul Hukuku Hakkında Kanun) provides two routes. Recognition (tanıma) makes the foreign judgment evidence of a legal status, which is what you need to be recorded as divorced or to have a parentage finding accepted. Enforcement (tenfiz) goes further and allows the judgment to be executed in Türkiye through the enforcement offices, which is what you need to collect maintenance, enforce a financial order or a money judgment, or have a custody order acted on. Tenfiz includes tanıma; a party who needs enforcement asks for both.

The court is the civil court of first instance, and for family matters the family court (aile mahkemesi), in the district where the defendant lives or, if the defendant is not in Türkiye, in Ankara, İstanbul or İzmir.

When you need it rather than Article 27/A

For a plain divorce the administrative route under Article 27/A is quicker and cheaper. You come to court when the registry has refused the 27/A application, when the former spouse will not apply, when the decree was given in default, or when the judgment contains anything beyond the dissolution itself: child arrangements, spousal or child maintenance, a lump-sum or property adjustment order, or costs.

What the court examines

The Turkish judge does not re-try the case. Under Law 5718 the court checks that the foreign judgment is final under the law of the country where it was given, that reciprocity exists between Türkiye and that country (established with the UK in practice), that the subject matter was not within the exclusive jurisdiction of Turkish courts, that the judgment is not manifestly contrary to Turkish public policy, and that the defendant was properly summoned and able to defend.

Documents for the court file

• The judgment or order, sealed by the UK court, with an FCDO apostille (court documents qualify for the e-Apostille) and a Turkish translation notarised in Türkiye.
• Evidence of finality: the final order itself or a certificate from the court that no appeal is pending.
• Evidence of service on the defendant in the UK proceedings, apostilled and translated where it is a court document.
• A power of attorney for your Turkish lawyer, made at a consulate notary unit or before a UK notary with apostille and notarised translation, expressly authorising tanıma and tenfiz proceedings.
• Identity documents and nüfus kayıt örneği of the Turkish party.

Translations for a Turkish court are made by a translator sworn before a Turkish notary and notarised in Türkiye; a UK certified translation is not accepted and the consulate's translator register is not what the court asks for either. Apostille first, then translation, because the apostille is part of the document the court reads.

Timeline and outcome

An uncontested recognition case with a properly prepared file can be decided at the first or second hearing, often within three to six months, and the decision becomes final after the appeal period. A contested tenfiz, or one where the defendant must be served abroad, takes longer, sometimes over a year. Once final, a recognised divorce is entered in the family register, and an enforcement order is taken to the enforcement office (icra dairesi) like a Turkish judgment.

Documents you will need

• Decree absolute or final order translation
• UK court orders translation for custody, maintenance and financial orders
• UK power of attorney translation

Common pitfalls

• Translating only the order and not the judgment the court wants.
• An apostille on a photocopy rather than on a sealed court copy.
• A power of attorney that mentions divorce but not recognition proceedings.
• Translations certified in the UK, which the court sends back.
• Assuming a UK maintenance order can be collected in Türkiye without tenfiz.

What we provide and the cost

We prepare the Turkish translations for the court file: judgment, orders, service evidence and the power of attorney, each translated with its apostille by a translator sworn before an Ankara notary and notarised. Translation is from £6.50 per page of 1,000 characters; a final order is one to two pages, a full judgment with financial order four to ten pages (£26 to £65), a power of attorney two to three. The Ankara notary tariff is passed through at cost, about £13.50 per page in 2026, plus £5 handling per document, and an apostille of the translation, which some courts request, is £15. The PDF comes by e-mail and the wet-sealed originals go by courier for £30, normally straight to your lawyer's office in Türkiye. No UK VAT is charged and there is no collection. Our legal translation page describes how we handle UK court terminology in Turkish.