Debt Collection in Türkiye for Foreign Creditors: How Enforcement Works and Which Route Fits Your File

The three enforcement routes, the deadlines that kill a file, and what a foreign judgment is worth here.

A foreign supplier owed money by a Turkish company does not need a court judgment, an arbitral award, or even a written contract to start collecting. Türkiye’s default route is ordinary enforcement (ilamsız icra takibi): you file a takip talebi with an enforcement office (icra dairesi) under the Enforcement and Bankruptcy Law No. 2004, and if the statutory conditions are met an ödeme emri (payment order) is issued and sent to the debtor within at most three days, giving him seven days to pay (İİK arts. 58, 60, 61). The catch sits in the same seven days: the debtor may object without giving any reason, and a timely objection stops the proceeding outright (İİK arts. 62, 66). Everything that follows — which route you pick, what documents you hold, how fast you move — is really about controlling what happens in that window.

How does enforcement start when you have no judgment?

The takip talebi may be filed in writing, orally or electronically (İİK art. 58). One point matters disproportionately to foreign creditors: art. 58/1 requires a creditor resident abroad to state an address for service in Türkiye, and if none is given, the enforcement office’s own address is deemed to be the creditor’s. A creditor who overlooks this is, in practical terms, served at an office it never visits — and the deadlines below still run.

The payment order orders the debtor to pay the debt and costs into the enforcement office’s bank account within seven days, requires him to state expressly within the same seven days if the signature on the underlying deed is not his, and warns that enforcement continues if he neither pays nor objects (İİK art. 60). Before any of that, and often before the debtor knows anything, a creditor of a matured, unsecured money debt can apply for ihtiyati haciz (interim attachment) over the debtor’s movables, immovables and receivables, including receivables held by third parties (İİK art. 257). The court decides on evidence satisfying it as to the claim and may or may not hear the parties (İİK art. 258) — which is what makes it useful before the debtor has time to move assets.

What happens when the debtor objects?

The objection goes to the enforcement office, not a court, within seven days of service, in writing or orally, and in ordinary enforcement needs no reasons. A partial objection must specify which part and how much, or it is deemed not made; a denial of signature must be stated separately and expressly, failing which the signature is treated as accepted for enforcement purposes (İİK art. 62). The debtor must also give a Turkish domestic address with the objection. The objection is then served on you by a muhtıra within three days, and that service starts your own clock:

• İtirazın iptali — an action before the general court (the commercial court where the matter is commercial), within one year of service of the objection, proving the claim under general provisions (İİK art. 67). Missing the year does not extinguish the debt; you keep the right to sue under general provisions.
• İtirazın kesin olarak kaldırılması — an application to the icra mahkemesi within six months, available only where the claim rests on a deed containing an acknowledgment of debt with an admitted or notarially certified signature, or on an official document issued in due form (İİK art. 68). Miss the six months and a fresh ilamsız takip cannot be brought for the same claim.
• İtirazın geçici olarak kaldırılması — the variant for a private document whose signature the debtor denied, also six months (İİK art. 68/a).

In all three, icra inkar tazminatı of not less than 20% of the amount in issue is awarded against the losing side on the other party’s request, but the test differs by route. In an itirazın iptali action the debtor pays where his objection is found unjustified, and the creditor pays where he is found to have pursued enforcement wrongfully and in bad faith (İİK art. 67/2). Before the icra mahkemesi the debtor pays where the removal request is granted on substantive grounds and the creditor pays where it is rejected on substantive grounds (İİK arts. 68, 68/a). That threshold was reduced from 40% to 20% by Law No. 6352 of 2012. One tactical point in the creditor’s favour: at the removal hearing the debtor may not change or extend his grounds of objection beyond what appears from the text of the deed relied on (İİK art. 63). Whether a commercial money claim must first pass through mediation before an action is filed is a separate threshold question, addressed in our guide to mandatory mediation in Turkish law. The same provisions run the other way for a company that has been named as the debtor: the seven-day window, the negative declaratory action and the fact that the 20 per cent indemnity can fall on either side are set out in receiving a payment order in Türkiye, and that side of the work is our enforcement defence practice.

Does a cheque or promissory note change anything?

Substantially. A claim based on a cheque (çek), bill of exchange (poliçe) or promissory note (bono) may be pursued through the special attachment route reserved for negotiable instruments (İİK art. 167), filing the original instrument with the takip talebi. The payment order gives ten days to pay, but the debtor gets only five days to object — and he must object to the icra mahkemesi, not the enforcement office, and with reasons: that the instrument does not qualify as a kambiyo senedi, that the signature is not his (by written petition), or that he is not the debtor, the debt is extinguished, time was granted, the claim is time-barred, or the office lacks jurisdiction (İİK art. 168).

The decisive difference is what an objection does. On this route it does not automatically stop enforcement. A signature denial “satıştan başka icra takip muamelelerini durdurmaz” — it halts only the sale; the icra mahkemesi may order a provisional stay after a preliminary examination of the file (İİK arts. 169/a, 170). And a false denial is expensive: if the signature is found to be the debtor’s after a provisional stay, he pays not less than 20% inkar tazminatı plus a judicial fine of 10% of the claim (İİK art. 170/3).

The three enforcement routes compared

What is a foreign judgment or arbitral award worth here?

It is worth a great deal — but only after a Turkish court says so. Under the Act on Private International and Procedural Law No. 5718 (MÖHUK), a foreign civil judgment that has become final under the law of the rendering state can be executed in Türkiye only if a competent Turkish court grants tenfiz (art. 50); once granted, the judgment “is executed like a judgment given by Turkish courts” (art. 57/1), which places it on the ilamlı route. The competent court is the asliye mahkemesi at the respondent’s Turkish domicile or residence, or failing that Ankara, İstanbul or İzmir (art. 51), and art. 54 sets the conditions — reciprocity, no exclusive Turkish jurisdiction, no manifest breach of Turkish public order, proper service and representation abroad. For mere recognition (tanıma), the reciprocity condition does not apply (art. 58). Foreign arbitral awards run in parallel under arts. 60 to 62, and MÖHUK art. 1(2) preserves the international conventions to which Türkiye is a party, so the 1958 New York Convention governs awards within its scope. Both routes are treated in detail in our guides to enforcement of foreign judgments in Türkiye and enforcing foreign arbitral awards.

Interest, limitation and the deadlines that quietly kill a file

Interest is where a Turkish claim gains or loses real value. Article 1 of Law No. 3095 was rewritten by Law No. 7589 with effect from 31 July 2026: statutory interest is no longer a fixed percentage but 80% of the Central Bank’s short-term credit rediscount rate as at 31 December of the preceding year.

On limitation, the Turkish Code of Obligations No. 6098 sets a general ten-year period running from when the claim falls due, which the parties cannot vary by contract (arts. 146, 148, 149), with a five-year list covering rent and periodic performances, agency and commission contracts, and works contracts (art. 147). The Turkish Commercial Code No. 6102 runs a separate regime for instruments: three years against the acceptor of a bill, one year for the holder against endorsers and the drawer, and three years on cheque recourse claims (arts. 749, 814).

The deadlines that most often destroy a good claim are procedural, not substantive. An interim attachment lapses automatically if execution is not requested from the enforcement office within ten days of the order (İİK art. 261), and a creditor who obtained it before suing must file a takip talebi or an action within seven days of the attachment (İİK art. 264). The right to request attachment lapses one year after service of the payment order (İİK art. 78), and if sale is not requested within one year of the attachment, the attachment itself lapses (İİK arts. 106, 110). None of these clocks stops because a foreign creditor was waiting for a settlement call.

Where the money actually comes from

Once the objection stage is behind you, enforcement becomes practical rather than doctrinal: the enforcement office carries out attachment within at most three days of the request (İİK art. 79), the debtor’s assets, rights and receivables can be queried through the UYAP-integrated systems, and electronic attachment (e-haciz) can be requested. Realisation then depends on the sale rules in İİK art. 106, as replaced by Law No. 7343 of 2021, which require valuation and sale costs to be paid in full and in advance with the sale request. If the debtor’s problem turns out to be systemic rather than a single unpaid invoice, the analysis shifts to konkordato and financial restructuring, where a creditor’s leverage looks very different. Where the underlying relationship is a terminated distributorship, the claim is often larger than the invoices — see our guide to termination indemnity in distribution and agency. Attachment can also catch goods that do not belong to the debtor at all — leased machinery, tooling on loan, consignment stock — and the owner’s route to release them is the third-party ownership claim, which closes in seven days.

The choice between the three routes is usually made in the first meeting, and it is mostly determined by what is already in the file: a cheque or note points to the kambiyo route, an acknowledged or notarised deed points to a six-month removal application, and everything else starts as ordinary enforcement with an eye on the seven-day window. Our debt collection practice and commercial litigation and arbitration practice work on that sequencing — securing assets first, choosing the route second, and treating each statutory period as the hard date it is.

Which Route Fits Your File: The Debt-Collection Library

This guide explains the general machinery. Most files, however, turn on one specific document or one specific move by the debtor, and each of those has its own detailed guide on this site, written against the current statutory text. Start from what you hold and what the debtor is doing:

Two points cut across every row. First, the documents decide the speed: a negotiable instrument or a notarised acknowledgment of debt opens routes where an objection costs the debtor more than it costs you, while a claim that rests on emails and invoices will usually pass through mediation and a full action. Second, the deadlines run regardless of where the creditor sits: ten days to execute an interim attachment (EBL Art. 261), seven days to follow it with an enforcement request or action (EBL Art. 264), one year to request attachment after the payment order is served (EBL Art. 78), and one year from attachment to request the sale (EBL Art. 106). A file that is well chosen but slowly run loses the same way as a file that was chosen badly.

Related Practice Areas

• Commercial Debt Collection & Asset Recovery
• Enforcement of Foreign Judgments & Arbitral Awards
• Commercial Fraud & White-Collar Crime
• Commercial Litigation & Arbitration