Pursuant to the Law on Private International Law and Procedural Law, and the Law on the Approval of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards Law No. 3731, judgments rendered by foreign courts are not automatically valid in Turkiye.
In order for a judgment rendered by a foreign court to be enforceable in Turkiye, a separate lawsuit must be filed. This is known as a recognition and enforcement lawsuit.
Recognition refers to the acceptance of acourt decision as a final judgment. Enforcement, on the other hand, means that the judgment is made enforceable. For example, if a divorce decree includes an order for alimony payments, recognition alone is not sufficient to collect the alimony; enforcement is also required.
The recognition and enforcement of foreign arbitral awards in Turkiye is limited to merely commercial disputes, and the decision must have acquired enforceability. Whether a dispute qualifies as commercial or not will be determined in accordance with the Turkish Commercial Code.