Obtaining a maintenance judgment in Türkiye does not automatically lead to attachment in the foreign country where the debtor is located. For collection, the route by which the judgment will be recognized and enforced in the relevant country must be determined and, where necessary, an application must be made through a central authority. Before the debtor’s citizenship, it matters where the debtor lives and where the debtor’s income and attachable assets are located.
This guide focuses on a person who holds a Turkish maintenance judgment and wants to obtain payment abroad. If there is no judgment yet, an application to establish a decision under the applicable system may also be possible; this option is separate from an application to enforce an existing judgment. Because country lists and document requirements can change, the current official country information should be checked before the file is sent. [1, 2]
How are the judgment and the debtor reviewed before choosing a collection route?
The part of the judgment that concerns maintenance must be read, not only the divorce ruling. The beneficiary, the amount, the currency, the start date, the payment frequency, and the annual increase mechanism are identified. Any later reduction, increase, termination, or appellate decision is assessed together with it. An account showing which periods the debtor has paid is one of the core parts of the application.
If the debtor’s address is missing, the last known address, the employer, the date of birth, and other lawfully obtained identifying information are prepared. When the address is unknown, it may be possible under the applicable central authority arrangement to request assistance in locating the debtor. On the other hand, knowing only the name of a country does not mean that every account and asset in that country will be found automatically. [1, Art. 6–7]
When can the 2007 Hague Convention be used?
The Convention, which entered into force for Türkiye on February 1, 2017, facilitates the transmission of maintenance applications between states and the recognition and collection of decisions. In an application, entry into force with respect to both Türkiye and the requested country, the type of maintenance, and country declarations are checked. In federal or regional legal systems, whether the Convention applies to the relevant region is also important. [1, 2]
The scope of child maintenance and spousal maintenance is not the same
The core scope of the Convention is parent-child maintenance for persons under 21; permitted age reservations are checked separately. Recognition and enforcement of spousal maintenance connected to child maintenance is not assessed in the same scope as a stand-alone spousal maintenance application. In particular, the application of the parts concerning central authorities and legal assistance may vary.
Türkiye has declarations extending the scope to children under 25 who are in education, to certain disabilities, to spouses, and to parents in need. However, the extended scope is examined together with the corresponding declaration of the other state regarding the same obligations and Convention chapters. It cannot be said, based on Türkiye’s declaration, that every kind of family maintenance will be collected through the same route in every country. [2]
The country check should not rely on an old list alone
| Example country or group of countries | First check as of October 14, 2026 | Point to be examined separately in the file |
|---|---|---|
| Germany, France, the Netherlands | Relationship under the 2007 Convention through the EU | Type of maintenance, declarations, and local procedure |
| United Kingdom | Independent party status and current country information | Relevant legal territory and competent authority |
| Denmark | In force as of October 1, 2025 | The old EU exception information is not sufficient |
| Canada | Start of party status as of February 1, 2024 | Record of extension to the relevant province/territory |
| A country outside the 2007 system | Research into another convention or local law | 1973, 1956, and bilateral arrangements are separate |
This table is not a final acceptance decision for any file. Records of accession, entry into force, objections, reservations, and regional extension should be compared again on the date of the application. A state’s signing of a convention does not by itself show that the convention has begun to apply between Türkiye and that state.
How does an application through the central authority proceed?
Article 9 of the 2007 Convention routes the application through the central authority of the contracting state where the applicant resides to the central authority of the requested state. Citizenship alone does not determine the transmitting authority. Official information on maintenance cooperation in Türkiye can be followed through the Maintenance Office of the Ministry of Justice General Directorate for Foreign Relations and the European Union (Adalet Bakanlığı Dış İlişkiler ve Avrupa Birliği Genel Müdürlüğü) and its relevant circulars. The local transmission channel that suits the country and the convention should be confirmed before the application documents are sent. [1, 3]
The type of application must be chosen clearly: recognition and enforcement of an existing decision, enforcement of an already recognized decision, or, under the necessary conditions, establishing a decision are not the same form purpose. The Convention also provides separate application types for a creditor or debtor who wants to modify a decision; these do not override the jurisdiction rules of the state concerned. [1, Art. 10]
Central authorities may assist with completing the application, locating the debtor, investigating income and assets, and transferring payments. This cooperation does not remove the powers of the foreign country’s courts and enforcement authorities. To reduce unnecessary correspondence, a single, consistent identity and periodic account file should be attached to the application.
Which documents should be prepared?
| Document group | Content | Common deficiency |
|---|---|---|
| Judgment and later rulings | Full judgment, amendments, and appellate decisions | Submitting only the divorce page |
| Enforceability and service | Official documents required by the relevant regime | Treating finality as the only criterion everywhere |
| Claim calculation | Month, amount, increase, payment, and remaining debt | Writing a lump-sum figure without explanation |
| Identity and address | Information on the beneficiary, representative, and debtor | Not stating the child’s current situation |
| Payment and contact | Suitable bank and secure contact information | Mismatch of name or account holder |
| Translation and forms | Language and form accepted by the country | Sending English documents to every country |
Article 25 of the 2007 Convention regulates documents such as the text of the decision, its enforceability, notice and opportunity to defend where required, and information on arrears and indexation. The request for a fully certified copy and the country declarations are checked separately. The enforceability of a Turkish judgment is determined according to its own nature; interim maintenance and the ancillary ruling of a divorce should not be reduced to the same assessment. [1]
How are translation, apostille, and power of attorney handled?
No authentication or similar formality is required for documents within the scope of Article 38 of the 2007 Convention. While this exemption applies, a general recommendation such as “First have every document apostilled” would not be correct. In the case of another application route, the document verification rules of that route are examined. Translation is not the same thing as the exemption; Article 44 and the country explanations determine which language is accepted.
The need for a power of attorney or representation document is assessed according to the form of the application. The current version of the official form should be used, and personal data that the country does not request should not be shared unnecessarily. If there is a risk of domestic violence or to safety, it must be stated from the outset that disclosure of the address and other information may create danger; Articles 40–41 of the Convention contain data and safety protections.
How are accrued maintenance and payments calculated?
For each period, the amount awarded, the applicable increase, any interest, the payment made, and the balance should be shown separately. If the payment was made in a different currency, it is explained on what date and under which legal calculation rule it was set off. Collections in the Turkish file and collections in the foreign country should be compared regularly. Although the same debt may be tracked in two countries, collection of the same claim twice cannot be requested.
Article 32(5) of the 2007 Convention takes as the basis, for limitation periods in the enforcement of accrued claims, whichever of the laws of the state of origin and the requested state provides the longer period. This special provision prevents a fixed Turkish limitation period from being written into every international file. Article 56 should also be examined regarding the temporal application of the Convention and installments before its entry into force; the special rule on child maintenance and other maintenance should not be given the same outcome. [1]
In a hypothetical example, the total of three installments of 300 euros per month is 900 euros; if 200 euros have been paid for these periods, the starting balance, excluding interest and increases, is 700 euros. This simple example does not show which interest or exchange rate rule a court will apply. In a real file, the operative part of the judgment and the relevant law are the basis.
What should be expected regarding time, costs, and legal aid?
The six-week acknowledgment of receipt and the three-monthly status report under Article 12 of the 2007 Convention do not mean that maintenance will necessarily be paid within these periods. Service of documents, locating the debtor, objections, recognition and enforcement, and local enforcement steps affect the total duration. A fixed collection date cannot be promised.
Article 8 is considered for central authority services, and Articles 14–17 for access to justice and legal aid. Assistance under Article 15 is particularly important for parent-child maintenance for persons under 21; the scope, exceptions, and the relevant country declarations are checked. It should not be assumed that every adult maintenance claim, every direct application, and every translation is entirely free of charge in the same way. Although a direct application to the competent authority may be possible under Article 37, it does not automatically carry all the advantages of the central authority route.
How does the Court of Cassation decision distinguish cooperation from direct enforcement?
In the earlier reversal stage reported in the decision of the 2nd Civil Chamber of the Court of Cassation (Yargıtay 2. Hukuk Dairesi) dated April 2, 2024, E.2024/2612, K.2024/2311, it was stated that the 1956 New York Convention facilitates the collection of maintenance but does not by itself ensure direct enforcement of a foreign judgment in another country. The case concerns the enforcement in Türkiye of a foreign decision; it is not a general ruling on how a Turkish decision is to be enforced in every foreign country. [4]
The contribution of this decision to preparing an application is to avoid confusing the cooperation channel with the enforceability of the judgment. In a Turkish maintenance file sent abroad as well, the recognition, enforcement, and execution mechanism of the target country must be determined separately. The final outcome of the 2024 decision is the rejection of the request for rectification of the decision; the earlier stages reported do not replace a current review of the convention.
Conclusion
A strong file for collection abroad consists of the right choice of country and convention, an enforceable judgment, proper service documents, and an auditable debt calculation. The central authority route offers an important convenience but does not guarantee collection. Reporting all payments made after the application and meeting the document requests of the country authorities on time are important for the continuity of the process.
Related articles: Maintenance from a Spouse or Parent Living Abroad: Competent Court, Applicable Law, and Service of Documents; Recognition and Enforcement in Türkiye of a Foreign Court’s Maintenance Judgment; Increasing, Reducing, or Terminating a Foreign Maintenance Judgment: In Which Country Is the Case Filed?; What Happens If Maintenance Is Not Paid? Enforcement Proceedings, Accrued Maintenance, and Coercive Imprisonment; How Is Child Maintenance Collected from Abroad?.
Frequently Asked Questions
Can a Turkish enforcement office directly attach a salary in a foreign country?
Compulsory enforcement in a foreign country is carried out through that country’s competent authorities and the applicable international framework.
Is it enough that the debtor is a Turkish citizen?
No. The country of collection, the location of the income and assets, and the applicable convention are determined separately.
Can central authority assistance be obtained when I have no judgment?
If the applicable Convention and the type of application allow it, assistance in establishing a decision is possible; this differs from enforcing an existing judgment.
Can all documents be prepared in English?
The language accepted by the country and the translation requirements should be checked. English is not sufficient for every state.
Is an apostille absolutely required for the application?
The exemption from authentication under the 2007 Convention should be taken into account. Different conditions may apply in other routes.
Will payment arrive within six weeks?
The six-week provision concerns the acknowledgment of receipt; it is not a guarantee of payment or of the outcome of the file.
Is there no route left once the child passes the age of 21?
Convention declarations, other agreements, local law, and the substantive right to maintenance are examined separately. The age limit does not mean that all routes have ended.
If the debtor hides the address, is the application pointless?
No. Assistance in locating the debtor may be considered within appropriate cooperation; identity and known address information are important.
How is money collected in two countries tracked?
Payment records for the same periods are consolidated and reported to the relevant files. Duplicate collection must be prevented.
Can I apply directly in a foreign country through a lawyer?
A direct application may be considered under the procedure of the country concerned and Article 37 of the Convention; the cost and assistance conditions may differ from the central authority route.
References
- HCCH, 2007 Convention on the International Recovery of Child Support and Other Forms of Family Maintenance (Nafaka Tahsili Sözleşmesi), Arts. 2, 6–17, 25, 32, 37–44, 48–49 and 56. Full text.
- HCCH, records of status, declarations, reservations, and regional application of the 2007 Convention. Official table.
- Ministry of Justice, General Directorate for Foreign Relations and the European Union (Adalet Bakanlığı DİABGM), Maintenance Office (Nafaka Bürosu) and Circular No. 64/2 and its annexes. The old circular is assessed together with the current records of status and scope of the 2007 Convention.
- Court of Cassation 2nd Civil Chamber (Yargıtay 2. HD), April 2, 2024, E.2024/2612, K.2024/2311. Full text of the decision.
- Mesut Aygün and Gözde Çağlayan Aygün, “The Hague Convention on the International Recovery of Child Support and Other Forms of Family Maintenance” (Çocuk Nafakası ve Diğer Aile Nafaka Türlerinin Uluslararası Tahsiline İlişkin La Haye Sözleşmesi), İnönü University Faculty of Law Journal, 9/2, 2018. Doctrinal background; not used in place of the current country list. Academic study.
Source check date: October 14, 2026.