This guide compares signing at a Turkish Consulate General in London, Manchester or Edinburgh with signing before a UK notary or solicitor and obtaining an FCDO apostille, and explains translation, the powers Turkish law wants spelled out, and revocation.
From the UK you can give a power of attorney for Türkiye in one of two ways: sign it at one of the three Turkish Consulates General (London, Manchester or Edinburgh), where it needs no apostille, or sign it before a UK notary or solicitor and have the FCDO Legalisation Office add an apostille. A consular power is a Turkish notarial act, because under the Notaries Act (Law No. 1512) notarial work abroad is done by consuls (Article 191) inside the consulate building (Article 192). A power signed before a UK notary is a foreign document: HMK Article 224(1) makes the official status of a foreign official document in Türkiye depend on certification, and Article 224(2) reserves the certification rules of treaties to which Türkiye is a party. The 1961 Hague Apostille Convention is one of them, so the apostille is enough. Either way, if the agent will sell or transfer land, the power must say so expressly, because an agent who is not specially authorised may not transfer an immovable (Turkish Code of Obligations, Law No. 6098, Article 504(3)).
Three files from the United Kingdom show why the form of a power of attorney matters. A retired couple in Kent want to sell the villa in Fethiye they bought years ago, without another trip to Dalaman. A British-Turkish nurse in north London has to deal with her late father’s flat in Kayseri, which she now owns with her two brothers. A limited company registered in Scotland wants a lawyer in Istanbul to sue a Turkish customer over unpaid invoices. In each case someone in Türkiye has to sign, apply or attend court for them, under a power of attorney (vekâletname) that the receiving office will act on.
A resident of the UK can produce such a power in one of two ways. You can sign it at one of Türkiye’s Consulates General in London, Manchester or Edinburgh, where the consul draws it up in Turkish as a Turkish notarial act. Or you can sign before a notary public or a solicitor near home, have the FCDO Legalisation Office (part of the Foreign, Commonwealth and Development Office) attach an apostille, and have the whole package translated into Turkish once it arrives in Türkiye. The Apostille Convention has applied to the United Kingdom since 24 January 1965 and to Türkiye since 29 September 1985, so the second route does not need a further certificate from a Turkish consulate.
The better choice depends on what the agent will do with the power. This guide starts from that question and then follows the three files.
How do I give a power of attorney from the UK for use in Turkey, and does it need an apostille?
Start from what the agent will do. At a consulate the consul draws the power up in Turkish, as a Turkish notary would, so it goes to Türkiye without an apostille or a translation. A power signed before a UK notary or solicitor needs the FCDO apostille and, once in Türkiye, a Turkish translation; no further certificate from a Turkish consulate is needed (HMK Article 224(2)). For a land registry transaction, the registry asks for a power drawn up under Law No. 1512 that authorises the very transaction applied for and bears the principal’s signature (Land Registry Regulation, Article 18(4)), so check with the registry through your lawyer before you choose the UK notary route.
Start with the Turkish office that will read the power
Every power of attorney ends up on a desk in Türkiye, and each desk applies its own rules. Knowing which office will act on yours tells you how the power has to be made.
- The land registry (tapu müdürlüğü). The Notaries Act requires contracts and powers of attorney that by their nature call for a transaction at the land registry to be drawn up by the notary in full (Notaries Act No. 1512, Article 89), not just signed in front of a notary. When an agent applies, the registry asks for a power drawn up under Law No. 1512 that shows the agent is authorised for the transaction requested; the principal’s signature must be on it, and the registry compares the principal with the registered owner (Land Registry Regulation, Tapu Sicili Tüzüğü, Article 18(4)).
- A court. The lawyer has to file the original power, certified or drawn up by a notary, or a copy the lawyer has certified against the original (Code of Civil Procedure, HMK, Article 76(1)). HMK Article 114(1)(f) makes a properly drawn-up power one of the procedural conditions (dava şartları) a court checks when a party litigates through an agent.
- A civil court of peace or a notary dealing with an estate. Certificates of inheritance are issued on application by a civil court of peace or by a notary (Turkish Civil Code, TMK, Article 598(1)).
- A company. In a Turkish limited company, the transfer of a share, and the transaction creating the obligation to transfer it, must be in writing with the parties’ signatures certified by a notary (Turkish Commercial Code, TTK, Article 595(1)); our guide to share transfers in a Turkish limited company covers the rest of that article. TTK Article 415(2) also makes a power of attorney a condition for the representative of a corporate shareholder who attends the general assembly of a Turkish joint stock company.
Signing at a Turkish Consulate General in the UK
Turkish law treats a consul abroad as the notary. Under Articles 191 and 192 of the Notaries Act, consuls carry out notarial work in foreign countries, inside the consulate building and under the Act’s rules on notarial acts. Article 193 lists which parts of the Act bind consuls, and they include Article 74 on interpreters and Articles 78 to 108, which contain the rules on drawn-up and certified acts. A consul can therefore produce the full notarial act that Article 89 asks for in property matters.
Article 84 sets out what the record of a drawn-up act contains: the notary’s name and office, the place and date, the identities and addresses of the person concerned and of any interpreter, witness or assessor (bilirkişi), the person’s tax identification number, the statement of what the person truly wants, and the signatures. The original of a drawn-up act stays at the office, and the person receives a copy (Article 84).
Which consulate covers where
Each consulate lists its own district on its contact page:
- London: London, the South East, the South West and the East of England, the Bailiwicks of Jersey and Guernsey, and the UK Overseas Territories.
- Manchester: the West Midlands, the East Midlands, Yorkshire and the Humber, North East and North West England, Wales and the Isle of Man.
- Edinburgh: Scotland and Northern Ireland.
All three contact pages send applicants to konsolosluk.gov.tr for an appointment. The Edinburgh consulate’s note of February 2020 says an appointment covers only the applicant’s own business, and the London consulate’s note of July 2026 says one appointment allows one notarial act.
What the London consulate’s note asks for
The London consulate published a notarial information note in July 2026. The points below come from that note; Manchester and Edinburgh may differ in detail, so check with them when you book.
- Turkish citizens bring the original Turkish identity card. For powers that include land registry transactions, the new-type identity card is required. For other powers, the note also accepts a passport, driving licence, Blue Card, or a member of parliament’s or lawyer’s identity card.
- You need the agent’s full name, date of birth, father’s name and Turkish identity number.
- Powers for land registry, divorce or vehicle sale matters need two recent passport photographs of the applicant.
- For selling or transferring property, bring a copy of the title deed or its registry details: province, district, neighbourhood or village, locality, map sheet, block, parcel, land share, floor, building block and independent unit number.
- For a power to a lawyer, bring the lawyer’s full name, bar association, Turkish identity number and date of birth.
- To reuse the wording of an earlier power, bring that text in Word format, or the earlier power’s journal number, date and notary office.
- Foreigners without Turkish citizenship may apply in person with their original passport and a sworn Turkish translator; the note links to the translator list on konsolosluk.gov.tr.
The note mentions company work only for companies established in Türkiye, for which it asks for the original of the company’s signature circular or a copy certified by a notary. It says nothing about powers given by UK companies, so a UK company should ask before booking or use the notary route below.
A consular power never goes to the FCDO. It is a Turkish act from the start, and Article 1 of the Convention leaves documents executed by diplomatic or consular agents outside its scope. If a Turkish office later wants to confirm a power issued in London, the consulate’s note says the request must come from that office’s official email address with a scan of the power attached.
Signing before a UK notary or solicitor, then the FCDO apostille
The second route keeps everything local until the package is posted. gov.uk states that documents such as a power of attorney can be legalised once a UK public official, such as a notary or solicitor, has certified them. It links to official lists of notaries and solicitors in England and Wales, in Scotland and in Northern Ireland. The Hague Conference lists a single competent authority for the UK, the FCDO Legalisation Office (with separate entries only for the Overseas Territories), so a power signed in Belfast, Cardiff or Aberdeen goes to the same office as one signed in London.
What the apostille certifies
According to gov.uk, the Legalisation Office checks whether the signatures, stamps or seals on a document match its records and, if they do, attaches the apostille. Articles 3 and 5 of the Convention define what is certified: that the signature is genuine, the capacity in which the signer acted and, where there is one, whose seal or stamp the document bears. It is placed on the document itself or on an attached sheet called an allonge (Article 4). Whether the text gives the agent enough authority is not something the apostille addresses; that stays a question of Turkish law.
Why no Turkish consular step is added
Article 195 of the Notaries Act provides that, under a notarial act done abroad according to local procedure, the signature and seal of that country’s competent authority are certified by the consul, with special statutory rules reserved. The HMK repeats the idea for foreign official documents: they carry that status in Türkiye once certified by the issuing state’s competent authority or by the relevant Turkish consulate (HMK Article 224(1)), and treaty rules on certification are reserved (Article 224(2)). The Apostille Convention is such a treaty. Each state party must exempt covered documents from consular legalisation, and the apostille is the only formality that may be required (Articles 2 and 3).
Paper or electronic
gov.uk offers a paper apostille and an e-Apostille. The electronic version needs PDF files electronically signed by a UK notary or solicitor, and gov.uk tells applicants to check with the person asking for the document which type they need. For a Turkish court, the lawyer files the original power or a copy the lawyer has certified (HMK Article 76(1)). Ask your lawyer in Türkiye before choosing the electronic version.
The land registry question
For a land registry power, settle the form before choosing a route. The Land Registry Regulation asks for a power drawn up under Law No. 1512 (Article 18(4)), and under Article 18(8) the General Directorate of Land Registry and Cadastre is the body competent to determine which documents are to be used in land registry and cadastre transactions by foreign nationals and by commercial companies with legal personality set up abroad under the law of their own country. This guide does not describe those internal instructions. Before a UK notary prepares a power for a sale or purchase, ask the land registry office where the property is registered, through your lawyer in Türkiye, which form it will accept and what it needs to see on the document.
Not the same as a lasting power of attorney
A lasting power of attorney (LPA) made in England and Wales is a different instrument from the power described in this guide. gov.uk describes an LPA as a legal document that lets you appoint one or more people to help you make decisions or to make decisions on your behalf, and states that it is legally binding only in England and Wales. Questions about an LPA itself belong to an adviser qualified in the relevant part of the UK.
The two routes side by side
| Point | Turkish Consulate General (London, Manchester, Edinburgh) | UK notary or solicitor, then FCDO apostille |
|---|---|---|
| What the document is | A Turkish notarial act (Notaries Act Articles 191 to 193) | A UK-certified document with an apostille (Apostille Convention Articles 3 and 5) |
| Language | Turkish, with a sworn interpreter if the signer does not know Turkish (Article 74) | English or bilingual; a certified Turkish translation is made in Türkiye |
| Land registry powers | Can be drawn up in the full form Article 89 requires | Ask the land registry office first (Land Registry Regulation Article 18(8)) |
| Who the published guidance addresses | Turkish citizens; foreigners in person with passport and sworn translator; companies established in Türkiye (London note) | Any document certified by a UK notary or solicitor (gov.uk) |
| Apostille | The Convention does not apply to consular documents (Article 1) | Issued by the FCDO Legalisation Office |
| What you hold afterwards | A copy of the drawn-up act; the original stays at the consulate (Article 84) | The signed document with the apostille on it or on an allonge (Convention Article 4) |
| Translation | Not needed for the power itself | The power, the notarial certificate and the apostille are all translated |
Three UK files and the powers they need
The Kent couple selling their villa in Fethiye
Both spouses are registered owners. Because the registry compares the registered owner with the principal named in the power (Land Registry Regulation Article 18(4)), each of them has to authorise the sale of his or her own share. Kent lies in the London consulate’s district, and as British citizens who do not speak Turkish they can use the note’s rule for foreigners: original passports, a sworn Turkish translator, two photographs each and the villa’s registry details. If they would rather sign in Kent before a notary, they should first get the land registry’s answer on the form, as explained above.
The wording matters more than the route. Unless specially authorised, an agent may not transfer an immovable or encumber it with a right (TBK Article 504(3)), so a power “to manage our affairs in Türkiye” will not do. The text should name the villa by its registry details and authorise the sale, signing the official deed at the registry, receiving the price into a named account and paying the costs of the transfer. If the agent should be able to appoint a substitute, say so: when a substitute acts, the registry also asks for the power that gave the right to appoint (Article 18(4)). The registry details for the power come from the title record itself, and the guide on reading a tapu record shows where each one appears.
A father’s flat in Kayseri, handled from north London
The nurse holds British and Turkish citizenship, and north London is in the London consulate’s district. The consulate will draw up her power, but its July 2026 note says it does not issue certificates of inheritance. That certificate comes from a civil court of peace or a notary in Türkiye (TMK Article 598(1)), and a notary may not issue it in situations that require adjudication, such as insufficient civil registry records, an application by foreigners, the need to hear witnesses or obtain an assessor’s examination, or a request with a foreign element (Regulation on Inheritance Certificates Issued by Notaries, Article 5(1)).
Once the father died, she and her brothers became joint owners of the whole estate. Where there are several heirs, they hold the estate jointly and dispose of its rights together, subject to any authority to represent or manage that arises from a contract or the law (TMK Article 640). Each heir may ask for the estate to be divided at any time, unless bound by contract or law to stay in the community (TMK Article 642(1)). So the agent she appoints needs authority for three things: applying for the certificate, having the heirs registered at the land registry, and carrying out whatever sale or division the siblings agree.
Debts change the timetable. The deadline to reject an inheritance is three months (TMK Article 606(1)), running for statutory heirs from the day they learned of the death unless they prove they only learned later that they were heirs (Article 606(2)). The rejection is made to the civil court of peace by oral or written declaration and cannot carry conditions (TMK Article 609). If an agent is to make that declaration, say so in plain words in the power. Registration, shares and the sale of an inherited flat are covered step by step in inheriting property in Türkiye as a UK heir.
A Scottish limited company suing a Turkish customer
The company’s director signs the power before a notary public at a solicitor’s office in Edinburgh, and the FCDO Legalisation Office attaches the apostille. A Turkish court will check that the lawyer holds a duly drawn-up power (HMK Article 114(1)(f)), so the file should also show that the director can bind the company. gov.uk lists a company certificate issued by Companies House among the documents the Legalisation Office can legalise; together with a board resolution certified by the notary, it gives the Turkish lawyer something to show.
Under HMK Article 73(1), authority to litigate runs until the judgment is final and takes in the steps of the case, enforcement of the judgment and collection of costs, with acts that need special authority reserved. HMK Article 74(1) names those acts; they include settling, challenging a judge, amending the whole claim, appointing another lawyer, lifting an attachment, entering into an arbitration agreement, using alternative dispute resolution, waiving the claim or an appeal, and releasing the other side or accepting its claim. The Code of Obligations adds that an agent may not sue at all without special authority (TBK Article 504(3)). Where waiting could cause harm, HMK Article 77(1) lets the court allow the lawyer to file or take steps first, provided the power follows within a final deadline the court fixes. Copies of the power that the lawyer certifies have the status of official copies for all courts, official offices and institutions, and natural and legal persons (Attorneys Act No. 1136, Article 56).
Security for costs is a further point. Foreign individuals and legal entities that sue, join a case or start enforcement proceedings in Türkiye must give the security the court sets for costs and the other side’s losses, and the court exempts a claimant on the basis of reciprocity (Law No. 5718 on Private International Law and Procedure, MÖHUK, Article 48). Whether a UK company qualifies for that exemption is a separate question to settle before filing; our guide for UK exporters recovering unpaid invoices looks at the claim itself.
Translation once the original reaches Türkiye
HMK Article 223 puts the translation burden on the party relying on a foreign-language document and lets the court ask for an official translation, of its own motion or at the other side’s request. Turkish notaries translate documents (Notaries Act Article 60(6)) and add a note under the translated text; where a sworn translator was used, the note gives that translator’s identity and address (Article 103). The Edinburgh consulate’s note of February 2020 says the consulates general do not translate and sends applicants to sworn translators.
For an apostilled power, have everything on the pages translated: the power, the notary’s certificate and the apostille. The Turkish reader then sees the full chain from the signer to the FCDO. A consular power is already in Turkish and needs no translation of its own.
Holding both British and Turkish citizenship, or a Blue Card
If you acquired British citizenship while keeping Turkish citizenship, a note that you hold more than one nationality is entered in your Turkish civil registry record once you present documents on the foreign citizenship and it is established that the records concern the same person (Turkish Citizenship Law No. 5901, Article 44(1)). Use the name and identity number shown in the Turkish register on the power. Where the right holder applying is a natural person, the land registry asks for an identity card bearing the Turkish identity number and compares its details with the civil registry details in the documents on which the registration rests (Land Registry Regulation Article 18(2)), and it makes the same comparison between the registered owner and the principal in a power (Article 18(4)).
If you were born Turkish and left Turkish citizenship with permission, you and your descendants up to the third degree keep the rights of Turkish citizens, apart from the exceptions in the article (Law No. 5901, Article 28(1)). Article 28(6) gives you a Blue Card if you ask for one, and under Article 28(8) the identity number assigned to you stands in for the Turkish identity number wherever one is required. The London consulate’s note of July 2026 accepts the Blue Card for powers that do not involve the land registry, but for land registry powers it asks for the new-type Turkish identity card. A Blue Card holder planning a property power should ask the consulate how it will handle the appointment before booking.
Revoking the power later
TBK Article 42 lets you narrow or take back the authority whenever you wish; waiving that right in advance is not possible. TBK Article 512 lets either side end the mandate itself whenever it wishes, but the side that ends it at an unsuitable time compensates the other’s resulting loss. When the authority ends, the agent must return the document or leave it where the court directs (TBK Article 44).
Two practical routes exist. At the consulate, you sign a revocation (azilname); the London note asks for the agent’s name and full Turkish address, the notary office that drew up the power, and the power’s date and journal number. From a UK notary, you sign a revocation, obtain the apostille, and have it translated and served in Türkiye through a Turkish notary, since sending notices is part of a notary’s work (Notaries Act Article 60(7)).
Then tell everyone who saw the power. Acts the agent performs before learning that the authority has ended bind you unless the third party knew (TBK Article 45), and you answer for the agent’s acts done before he or she learned that the mandate ended as though it had continued (TBK Article 514). A principal’s death also ends the authority as a rule, subject to the same exceptions as loss of capacity (TBK Articles 43 and 513(1)), which is why an heir needs a power of his or her own.
Lex Lata and clients in England, Scotland, Wales and Northern Ireland
Lex Lata’s work for people and companies in the UK covers Turkish property, estates, court cases and company matters. Its advice is limited to Turkish law; anything turning on English, Scottish or Northern Irish law, or on UK tax, should go to an adviser qualified there. Files are handled remotely, with correspondence in English. Türkiye stays on UTC+3 all year, so London is two hours behind Istanbul during British Summer Time and three hours behind in winter; the UK changes its clocks on the last Sunday of March and of October.
In practice Lex Lata drafts the Turkish wording first, sends an English working version for the client to read before the signing, and reviews the translated, apostilled set once the original reaches Istanbul. The guide for UK residents with a legal matter in Türkiye sets out the other areas, and the contact page is the way to reach Lex Lata.
