Enforcing an LMAA or other foreign arbitration award in Türkiye

An LMAA award against a Turkish owner or charterer is enforced in Türkiye under the New York Convention, to which Türkiye acceded with effect from 30 September 1992 subject to the reciprocity and commercial reservations (UNCITRAL status list, checked 17 September 2026), through a petition to the Turkish civil court under the Private International Law Act. The court does not re-hear the dispute; it checks the award against a closed list of grounds and, if none applies, declares it enforceable in Türkiye.

Where to file

1. The place the parties agreed in writing.
2. Absent agreement, the defendant's domicile in Türkiye, failing that its place of residence, failing that the place where assets capable of enforcement are located (Private International Law Act, art. 60).
3. Where a vessel has been arrested, the arrest court is itself competent to enforce the award while the vessel is within its district or the release security is with the court (TCC art. 1360).

What to file

• the original or a certified copy of the arbitration agreement or clause;
• the original or a certified copy of the award, showing that it is final, enforceable or binding under the law of the seat;
• certified translations of both (Private International Law Act, art. 61).

The award and the agreement are legalised for use in Türkiye by apostille, Türkiye being a party to the Hague Apostille Convention (HCCH status table, checked 17 September 2026), and translated by a sworn translator here.

What the court may refuse

Enforcement is refused only on the grounds in the Act (Private International Law Act, art. 62):

• there was no arbitration agreement or clause;
• the award is contrary to morality or public order;
• the dispute is not arbitrable under Turkish law;
• a party was not duly represented and did not later ratify the proceedings;
• a party was not properly notified of the appointment of the arbitrators or was deprived of the right to be heard;
• the arbitration agreement is invalid under the law the parties chose or, failing that, the law of the seat;
• the arbitrators or the procedure did not follow the parties' agreement or the law of the seat;
• the award goes beyond the agreement, as to that part;
• the award is not final, binding or enforceable under the law of the seat, or has been set aside there.

The defendant bears the burden of proving the grounds concerning representation, notice, validity, procedure, scope and finality (Private International Law Act, art. 62).

After the order

An award declared enforceable is executed like a Turkish judgment through the enforcement office: against bank accounts, receivables, real property and vessels. A vessel is sold under the rules for immovables if registered (TCC art. 1383).

Where the debtor's assets are a ship that calls at Turkish ports, the practical sequence is often the reverse — arrest first, then enforce the award against the security.TCC arts 1356, 1360

Updates to this guide