This guide explains the two routes (a Turkish consulate in the US, or a US notary followed by an apostille), which US authority issues the apostille, how the translation is made, what the Turkish text must authorize and how to revoke it.
A Turkish-American engineer in New Jersey wants to sell the flat in Izmir she inherited from her parents. A US LLC needs a lawyer in Istanbul to sue a distributor that stopped paying. A widow in Texas has to deal with her late husband’s share of a family house in Türkiye. None of them plans to fly over for the paperwork. Each needs a power of attorney (vekâletname) that the Turkish office at the other end will accept.
There are two ways to produce that document in the United States. The first is an appointment at a Turkish mission: the Embassy in Washington, D.C., or one of the Consulates General in Boston, Chicago, Houston, Los Angeles, Miami and New York. The power is then drawn up as a Turkish notarial act, in Turkish, and needs no further certification. The second keeps the signing local: you sign before a notary public in your own state, the competent US authority attaches an apostille, and the Turkish translation is certified once the original reaches Türkiye. The Apostille Convention has been in force for the United States since 15 October 1981 and for Türkiye since 29 September 1985, so Turkish consular legalization is not added on top of the apostille.
Which route is right depends less on convenience than on what the agent will do with the power: sign a sale at the land registry, file a lawsuit, apply for a certificate of inheritance, or vote shares. This guide works through those uses with the three examples above.
Matching the route to the job
The table is a starting point. The sections after it explain the rules behind each line.
| Situation in the US | Route that usually fits | Why | What the agent in Türkiye receives |
|---|---|---|---|
| Turkish citizen in New Jersey selling a flat in Izmir | Consulate General in New York | Land registry powers are drawn up in full notarial form, which a consul does as a Turkish notarial act | The original power by mail, or a copy from a Turkish notary if the power allows it |
| US citizen without Turkish, buying or selling property | Turkish consulate with a sworn interpreter, or US notary and apostille after checking the registry’s requirements | The consulate route matches the registry rule on powers drawn up under the Notaries Act | A consular power in Turkish, or an apostilled power with a certified translation |
| US LLC suing a Turkish distributor | US notary, then apostille | The New York and Los Angeles consulates state they do not draw up powers for foreign companies | The apostilled power, proof of the signer’s authority, certified translations |
| Widow in Texas handling her husband’s estate | Consulate General in Houston, or US notary and apostille | Both can work; the power has to name each inheritance step | A power naming the court or notary application, the registry transfer and any sale |
| Shareholder of a Turkish company voting or selling shares | Either route, depending on who signs | A legal entity’s representative must present a power at a joint stock company’s general assembly, and limited company share transfers need notarized signatures | A power naming the company, the shares and the acts |
| Anyone ending an earlier power | Consulate, or US notary and apostille | Revocation must reach the agent and every office that relied on the power | A revocation served through a Turkish notary |
The consulate route: a Turkish notarial act signed in the United States
Outside Türkiye, a Turkish consul does the work of a Turkish notary. The Notaries Act (Noterlik Kanunu, Law No. 1512) provides that notarial functions in foreign countries are performed by consuls (Article 191), inside the consulate building and under the Act’s provisions on notarial acts (Article 192). Article 193 lists the provisions that apply to consuls; the rules on drawn-up and certified acts (Articles 78 to 108) and the interpreter rule (Article 74) are among them.
This matters most for property. Article 89 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 (düzenleme şeklinde), rather than merely having the signature certified. A drawn-up act is a record containing, among other things, the identities and addresses of the person concerned and of any interpreter, witness or assessor (bilirkişi) taking part, the person’s tax identification number, and the statement of what the person actually wants (Article 84). A signature certification is narrower: it records that the signature belongs to the person who signed (Article 90). Because Articles 78 to 108 apply to consuls, a Turkish consul can produce the full drawn-up act.
Each mission serves a group of states. The Consulate General in New York covers New York, New Jersey, Delaware and Pennsylvania, so the New Jersey owner in our example books there. Houston covers Texas together with Arkansas, Alabama, Louisiana, Mississippi, New Mexico, Oklahoma and Tennessee. The consular section of the Embassy in Washington, D.C. serves the District of Columbia, Maryland, Virginia and West Virginia. Appointments are booked through the Turkish Foreign Ministry’s consular portal, konsolosluk.gov.tr.
The consulates’ own guidance notes are worth reading before the appointment. They ask for the agent’s full name, Turkish identity number and date of birth and, where the agent is a lawyer, the bar and registration details. They ask for two identical photos for land registry powers. If you want the power drawn up from your own draft, they ask for it in advance in an editable format such as Word. Their general notes state that a power is valid without a time limit unless one is requested at the start (the New York consulate’s 2026 note for foreigners and non-Turkish speakers says instead that those powers are to be drawn up for a fixed period), and that the agent can obtain a copy from a notary in Türkiye if the power includes that authority, which has to be requested at the outset.
If you do not speak Turkish, Article 74 requires a sworn interpreter to be present. The New York consulate’s 2026 note says that, for foreigners and for Turkish citizens who do not speak Turkish, it draws up powers only for land registry purchases and sales and for lawyer and court matters, only for individuals and not for foreign companies, and that appointments are booked through the translators named in the note.
The US notary route: notary, a county step in some states, then the apostille
Anyone can sign a power for Türkiye before a US notary public. The text is usually drafted in English and translated later. The apostille is what certifies the US notary’s signature and seal for use in Türkiye.
The Apostille Convention treats notarial acts, and official certificates placed on documents signed by persons in their private capacity, as public documents (Article 1). Between member states, the apostille is the only formality that may be required to certify the authenticity of the signature, the capacity in which the signer acted and, where appropriate, the identity of the seal or stamp (Article 3). Turkish procedure law points the same way. Under the Code of Civil Procedure (HMK, Law No. 6100), a document prepared by a foreign state’s authorities carries the quality of an official document in Türkiye once certified by the issuing state’s competent authority or the Turkish consulate (Article 224(1)), and the provisions of treaties to which Türkiye is a party on certifying foreign official documents are reserved (Article 224(2)). The New York and Chicago consulates’ notes say plainly that they do not certify the signature and seal on US-notarized powers: after the apostille, the document goes straight to Türkiye.
Who issues the apostille in the US
The competent authority depends on who issued or notarized the document. Documents issued by federal agencies receive their apostille from the U.S. Department of State’s Office of Authentications, and federal court documents are apostilled by the clerks of the federal courts. Documents issued or notarized under state law are apostilled by the authority each state designates, generally the Secretary of State; Alaska, for example, lists its Lieutenant Governor. For a notarized power, that means the state in which the notary holds the commission.
Some states add a step between the notary and the apostille. New York’s Department of State requires notarized documents to be certified first by the County Clerk of the county where the notary is qualified. In New Jersey, apostilles are issued by the Division of Revenue and Enterprise Services of the Department of the Treasury, which asks for documents bearing the original inked signatures of the New Jersey notary and of the signer. In Texas, the Secretary of State describes itself as the only agency in the state that issues apostilles for Texas public records. Forms and procedures change, so check the issuing state’s own page before the signing; the Turkish consulates’ notes also warn that the county clerk step applies in some states and not in others.
The Los Angeles consulate’s 2026 note on this route tells signers to fix a passport-size photo at the top right of the page and recommends asking the notary to stamp over it; it also asks for every page of a multi-page power to be signed and stamped separately, and for a copy of the Turkish identity card certified by the notary as a true copy.
Translation comes after the apostille
Turkish offices work in Turkish. Before a court, a party relying on a document written in a foreign language must file its translation (HMK Article 223(1)), and the court may, on its own motion or at the other side’s request, ask for an official translation (Article 223(2)). The translation covers the whole package: the power, the notary’s certificate, any county certificate and the apostille itself.
The usual practice is to send the apostilled original to Türkiye and translate it there. Translating documents from one language into another is one of a Turkish notary’s statutory functions (Notaries Act Article 60(6)); the notary places a note beneath the translation and, where a sworn translator was used, the note shows the translator’s identity and address (Article 103). The Chicago consulate’s note describes the alternative: a translation made in the United States must itself be notarized, county-certified where required and apostilled. Translating in Türkiye avoids that second chain.
What the power must allow the agent to do
Turkish law reads a power narrowly where the act is serious. Under the Turkish Code of Obligations (TBK, Law No. 6098), the scope of a mandate is determined by the nature of the business where the contract does not state it (Article 504(1)) and includes the legal acts needed to carry out that business (Article 504(2)). But an agent who is not specially authorized may not, among other acts, bring a lawsuit, settle, refer a matter to arbitration, stand surety, make a gift, or transfer an immovable or encumber it with a right (Article 504(3)). A general power is therefore not enough for the jobs most people in the US need done.
Selling the flat in Izmir
The New Jersey owner’s power should name the flat by its land registry details (province, district, neighborhood, block, parcel and unit number) and state expressly that the agent may sell it, sign the sale at the land registry and receive the price. The consulates also state that in a sale or purchase power the agent cannot be the person buying or selling, so the buyer cannot be appointed to sign for the owner.
At the registry, the request is examined to establish whether it comes from the right holder (Land Registry Regulation, Tapu Sicili Tüzüğü, Article 18(1)). Where the request is made through an agent, the registry asks for a power drawn up under the Notaries Act showing that the agent is authorized for the transaction requested; the principal’s signature must appear on it, and the registry compares the principal named in the power with the owner on record (Article 18(4)). The documents that foreign nationals and foreign companies use in registry transactions are set by the General Directorate of Land Registry and Cadastre (Article 18(8)). The consulate route meets the Notaries Act requirement in one step. The Los Angeles consulate’s note on company powers likewise offers the apostille method for everything except land registry transactions. If you would rather use a US notary and apostille for a registry transaction, ask the land registry office that will handle it, or the lawyer acting there, which form it will accept before you sign. Before any sale or purchase, it is worth reading the registry record itself: see how to read and verify a tapu.
Suing a Turkish distributor through a US LLC
A power for a lawsuit covers, until the judgment becomes final, every act needed to conduct the case, the enforcement of the judgment and the collection of costs (HMK Article 73(1)). Some acts still need express authority. HMK Article 74 lists them; among them are settling, challenging the judge, appointing another lawyer, lifting an attachment, concluding an arbitration agreement, resorting to alternative dispute resolution, waiving the claim or a legal remedy, and releasing the other side or accepting its claim. A litigation power for a company should name these acts expressly, because producing a new power with a fresh apostille takes time once a settlement is on the table.
The lawyer must file the original power certified or drawn up by a notary, or a copy the lawyer certifies (HMK Article 76(1)); copies of a power certified by the lawyer count as official copies before all courts, public offices and private persons (Attorneys Act, Law No. 1136, Article 56). Where a case is conducted through a representative, a duly drawn-up power is a condition of the action (HMK Article 114(1)(f)). Where delay could cause harm, the court may let the lawyer file the case or take procedural steps on condition that the power is produced within a final period the court sets (HMK Article 77(1)). That is a safety valve, not a plan.
Two US points follow. First, because the New York and Los Angeles consulates state that they do not draw up powers for foreign companies, a US LLC signs before a US notary and obtains an apostille. Second, the file should show that the person signing can act for the LLC: a document from the state registry on the company’s existence and a resolution or officer’s certificate naming the signer, each apostilled by the state that issued or notarized it. A foreign company that sues in a Turkish court must also provide the security the court sets for the costs of the proceedings and the other side’s loss, and Article 48(2) provides that the court exempts the claimant from security on the basis of reciprocity (Private International and Procedural Law Act, MÖHUK, Law No. 5718, Article 48). Collection cases are covered in our guide for US exporters with unpaid invoices; if the dispute has already produced a US judgment, see enforcing a US court judgment in Türkiye.
The widow in Texas
A power the husband gave during his lifetime does not carry over to the estate. Authority to represent granted by a legal transaction ends on the principal’s death unless otherwise agreed or implied by the nature of the business (TBK Article 43(1)), and a mandate ends automatically on the death of either party unless the contract or the nature of the business indicates otherwise (Article 513(1)). Acts the agent performed without knowing that the authority had ended still bind the heirs, unless the third party knew (Article 45), and the heirs are liable for the agent’s acts before he learned of the termination as though the contract had continued (Article 514).
The widow therefore needs her own power. The first step in Türkiye is usually the certificate of inheritance (mirasçılık belgesi), which a civil court of peace or a notary issues on application to those found to be statutory heirs (Turkish Civil Code, TMK, Law No. 4721, Article 598(1)). A notary may not issue it in situations that require adjudication, such as where the civil registry records are insufficient for the purpose, where it is requested by foreigners, where issuing it requires an expert examination or hearing witnesses, or where the request carries a foreign element (Regulation on the issue of certificates of inheritance by notaries, Article 5(1)); in those situations the certificate is sought from the civil court of peace. Her power should name each step: applying for the certificate, registering the heirs at the land registry, any sale of the share, and dealing with banks.
If the estate may carry debts, timing matters. An inheritance may be disclaimed within three months (TMK Article 606(1)); for statutory heirs the period runs from the date they learned of the death, unless it is shown that they learned only later that they were heirs (Article 606(2)). The disclaimer is made by an oral or written declaration to the civil court of peace and must be unconditional (Article 609). A power meant to cover a disclaimer should say so in plain words. Shares, heirs and the registry transfer are explained in our guide for US heirs inheriting property in Türkiye.
Company matters
Two rules in the Turkish Commercial Code (TTK, Law No. 6102) often bring company powers into play. At a joint stock company’s general assembly, representatives of legal entities must present a power of attorney (Article 415(2)). In a limited company, the transfer of a share and the transaction creating the obligation to transfer are made in writing, and the parties’ signatures are certified by a notary (Article 595(1)). A US parent holding shares in a Turkish subsidiary, or a Turkish-American selling a stake in a family company, needs a power that names the company, the shares and the acts. See also share transfers in a Turkish limited company.
Dual citizens, Turkish identity numbers and the Blue Card
Turkish-Americans who kept Turkish citizenship are Turkish citizens for every Turkish office. Where the person making a land registry request is an individual, the registry asks for the identity card bearing the Turkish identity number and compares it with the civil registry details in the registration documents (Land Registry Regulation Article 18(2)). The power should therefore carry the principal’s Turkish identity number and the name as it stands in the Turkish civil registry. The Los Angeles consulate’s note states that for every power that must be drawn up in full, including all land registry powers, it works only with the Turkish identity card, not with a passport.
If you acquired US citizenship, the Turkish Citizenship Act (Law No. 5901) provides that once you present the documents and the review finds you are the same person on the records, an annotation is made in your family register showing that you hold multiple citizenship (Article 44(1)).
Article 28 of the same Act covers people who were Turkish citizens by birth and gave up Turkish citizenship with permission, and their descendants up to the third degree: with the exceptions listed in that article, they continue to enjoy the rights of Turkish citizens (Article 28(1)). A Blue Card (Mavi Kart) is issued on request (Article 28(6)), and the identity number given to them is used wherever a Turkish identity number is asked for (Article 28(8)). If their identity details have changed, they must present a document from their state of nationality showing the old and new details together with its duly certified Turkish translation (Article 28(7)). The consulates’ notes ask Blue Card holders to use the card for their powers.
Ending a power from the United States
You may restrict or withdraw an authority to represent at any time, and you cannot waive that right in advance (TBK Article 42(1) and (2)). Either party may end a mandate at any time, but a party ending it at an inopportune moment must make good the other’s resulting loss (Article 512).
Ending a power is not the same as stopping it from working. You remain bound by acts of an agent who did not know the authority had ended, unless the third party knew (Article 45), and you are liable for the agent’s acts before the agent learned of the termination as though the contract had continued (Article 514). If you told a bank, the land registry or a business partner about the authority, you must tell them that it has been withdrawn, or you cannot rely on the withdrawal against third parties acting in good faith (Article 42(3)). The agent must return the written authority; if you fail to do what is needed to get it back, you answer for the loss of good-faith third parties (Article 44).
From the US, a revocation (azilname) can be drawn up at the consulate; the Chicago consulate’s note asks for the details of the power being revoked (where it was issued, its date and number) and the agent’s identity number and address. It can also be signed before a US notary and apostilled. Either way, it should be served on the agent through a Turkish notary, which sends protests, notices and warnings as one of its statutory functions (Notaries Act Article 60(7)). Where a lawyer is removed from a pending case, the removal takes effect for the court and the other side only once it is notified by petition or recorded in the minutes, with any service cost paid in advance (HMK Article 81(1)).
Five checks before the signing appointment
- Name the act. Write down what the agent will actually do: sell a named flat, sue a named company, apply for a certificate of inheritance, vote at a named general assembly. Then check the text covers each step, including the acts listed in TBK Article 504(3) and HMK Article 74.
- Match names and numbers. Use the name in the Turkish civil registry and your Turkish identity number or Blue Card number, and the agent’s full name, identity number and date of birth.
- Decide on limits. A time limit, a narrow scope and the authority to obtain copies from a Turkish notary all have to be requested when the power is drawn up.
- Know your state’s chain. For the notary route, confirm whether your state needs a county certificate before the apostille and which office issues the apostille.
- Plan the translation and the courier. Send the original by tracked mail and have the full package, apostille included, translated and certified in Türkiye.
Working with Lex Lata from the United States
Lex Lata acts for clients in the United States in Turkish land registry, litigation, inheritance and company matters. It advises on Turkish law only; questions of US law, including US tax, belong to a US-qualified adviser. Most of the work is done remotely and in English. Türkiye stays on the same time all year, so New York is seven hours behind Istanbul during US daylight saving time and eight in winter, Chicago eight and nine, and Los Angeles ten and eleven.
Lex Lata prepares the Turkish text of the power with an English working translation before the consulate appointment or the notary signing, so the wording matches the act it has to cover, and checks the apostilled package when it arrives in Türkiye. For the wider picture of handling a Turkish matter from the US, read our guide for Americans with a legal matter in Türkiye, or write to us through the contact page.
