Turkish citizenship by investment 2026 rules keep the 400,000 dollar threshold set in 2022 but change how property is valued, paid for and later reviewed.
Most of what is written about this program describes its prices. The prices have been stable for more than four years. What has moved is everything underneath them: who may value the property, how long the valuation document lives, which properties count at all, how the purchase money must enter the country, and what happens to a passport years after it was issued when the file behind it turns out to have been built on a false number.
The legal basis has not moved. Citizenship by investment rests on Article 12, paragraph 1, subparagraph (b) of Turkish Citizenship Law No. 5901 (Türk Vatandaşlığı Kanunu) and on Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law (Türk Vatandaşlığı Kanununun Uygulanmasına İlişkin Yönetmelik). The changes of 2023 to 2026 were made one level lower, through circulars and approvals of the Land Registry and Cadastre General Directorate (Tapu ve Kadastro Genel Müdürlüğü), and through the way the Ministry of Interior (İçişleri Bakanlığı) now reviews files that have already been granted.
What actually changed for investors in 2026? Three things. On 28 September 2026 the validity of the valuation document used for citizenship was extended from six to twelve months, and the requirement that the underlying report be prepared by GEDAŞ was lifted. Throughout the year, the authorities cancelled or withdrew citizenship decisions on a scale not seen before: on 4 August 2026 the Ministry of Interior reported 6,134 persons affected, most of them family members of investors whose files rested on irregular valuations.
Which version of a rule governs my own file? The version in force on the date of the relevant step, not the one in force on the day you read about it. The newest rule is often not the rule that decides your application, because each requirement attaches to a specific moment: the threshold to the date of purchase, the valuation period to the date of the land registry application, the currency route to the date the money moved. An investor who bought in 2021 and applies in 2026 is answering to several different years at once.
When does a change reach an application that is already under way? When the step it governs has not yet happened. A change to valuation rules matters only if the land registry application is still ahead of you; a change to the threshold matters only if the purchase is still ahead of you. The 28 September 2026 approval contains no express transitional provision, so files sitting across that date need to be read step by step.
How did the program become stricter while its price stood still? Through a kind of stable revision: the figure on every brochure stayed at 400,000 dollars while the verification behind that figure was rebuilt three times in three years. A fixed threshold measured by a moving method is a different threshold, and the 2026 revocations are what happens when the method catches up with files approved under an earlier, looser reading.
This page records those changes by date, so that an investor can tell which rule applies to which step of a file. It does not walk through the purchase procedure itself, which is set out in our guide to buying property in Turkey for citizenship, and the comparison of all seven investment routes, with the authority that certifies each, appears in the table further down this page. Oznur & Partners is recognised by The Legal 500 for its corporate immigration work in Turkey.
Reviewed by Fatih Oznur, Founding and Managing Partner, Oznur & Partners. Last reviewed: October 2026.
⚖️ What Changed in Turkish Citizenship by Investment in 2026?
Valuation, verification and review changed; the thresholds did not.
The year divides into two halves. In the first half, the Ministry of Interior and the investigating authorities turned toward files that had already been approved, cancelling investment conformity certificates where the transaction behind them was found to be collusive or irregular. In the second half, the Land Registry and Cadastre General Directorate changed the valuation regime that had been in place since March 2024, reopening the market of licensed valuation firms and doubling the life of the document on which every real estate application now depends.
Read together, the two halves tell one story. The 2024 rules had concentrated citizenship valuations in a single state-affiliated firm, GEDAŞ, and introduced the Value Determination Document (Taşınmaz Edinim Sureti İle Vatandaşlık Kazanımına Esas Tutar Tespit Belgesi, abbreviated TTB) as a system-generated record. The 2026 review of older files showed how much damage false valuations had done before those rules existed. The September changes then moved responsibility for the accuracy of each report squarely onto the valuation firm and the staff who sign it, while widening the choice of firm.
What the year did not do is equally important for planning under the Turkish citizenship by investment 2026 framework. The 400,000 dollar real estate threshold, the 500,000 dollar threshold for the deposit, government bond, fund, fixed capital and private pension routes, the three year holding commitment and the family scope of an application all stayed where they were. An investor reading a 2025 guide will find the prices correct and the procedure partly out of date, which is the more dangerous combination of the two.
⚖️ Which Rules Apply to My Application: the Date of Purchase or the Date of Filing?
Each rule attaches to its own date, and a single file can be governed by rules from different years.
Investors tend to think of a citizenship application as one event under one set of rules. It is in fact a sequence of steps spread over months, sometimes years, and each requirement is tested at the step to which it belongs. The threshold is tested against the purchase. The valuation period is tested against the land registry application. The currency route is tested against the moment the money was converted. The holding commitment runs from registration. None of these share a date by necessity.
The practical consequence shows up most clearly in older files. A buyer who acquired a property in 2019 for 260,000 dollars bought under the 250,000 dollar threshold that applied from 19 September 2018 until 12 June 2022, and that purchase is measured against that threshold, not against today’s 400,000. A buyer who signed in May 2022 and registered in July 2022 faces a different question entirely, because the registration fell after the 400,000 dollar rule took effect on 13 June 2022.
Valuation works the same way in miniature. A Value Determination Document issued in June 2026 was born under a six month rule; the land registry application it supports may be filed in November 2026 under a twelve month rule. Which period governs is a question about the wording of the amended guideline and the date of the application, and the answer changes the outcome for a document that is seven months old.
None of this is unusual in administrative law, but it is rarely explained to investors, because most guidance is written as a snapshot of today’s rules. A snapshot is accurate for a file that begins today and misleading for any file that began earlier. Before relying on any published summary, including this one, the useful question is not “is this current” but “current as of which step of my file”. Our note on how to obtain Turkish citizenship sets out the full sequence of steps to which these dates attach.
Started your file before September 2026? Check which rules still govern it.
Send us your purchase date, valuation date and planned appointment, and we will map each step against the rule that applies to it before you book anything.
⚖️ Can Citizenship Granted Through Investment Be Taken Back? The 2026 Revocations
Yes, and in 2026 it happened at scale: the Ministry of Interior reported on 4 August 2026 that the citizenship decisions of 6,134 persons had been cancelled or withdrawn.
The figures were published after an operation in 16 provinces concerning valuation reports alleged to have been falsified to support citizenship applications, in which 72 suspects were detained. According to the Ministry’s statement, the investment conformity certificates of 1,150 investors were cancelled where the transaction was found to be collusive or irregular, and the citizenship of those investors and their family members, 5,391 persons in total, was cancelled with them.
A second group was treated differently. For 263 investors and their family members, 743 persons in total, the citizenship decision was withdrawn on the ground that the legal conditions had not been met, following assessments by the General Directorate of Security (Emniyet Genel Müdürlüğü) and the National Intelligence Organisation (Milli İstihbarat Teşkilatı) on public order and national security. The statement cited Articles 31 and 40 of Law No. 5901 as the basis for the cancellations and withdrawals.
The same statement reported a narrower figure for the current year: since 11 February 2026, the investment conformity certificates of 443 investors had been cancelled, affecting 1,358 persons including family members, and 7 further persons had their citizenship withdrawn. The difference between the two sets of figures matters less than the direction they show. Review of an approved file is no longer a theoretical risk attached to the program; it is an operating feature of it.
For an investor whose file is clean, the lesson is not anxiety but record-keeping. A cancellation of this kind rests on the investment conformity certificate (Uygunluk Belgesi), and the certificate rests on the valuation, the declared price, the transfer receipts and the currency purchase document. An investor who can produce a consistent set of those records years after approval is in a very different position from one who cannot. Our analysis of Turkish citizenship revoked in 2026 examines the grounds and the available remedies in detail; this page records only the change in practice.
⚖️ The 28 September 2026 Valuation Changes: Twelve Months and the End of the GEDAŞ Requirement
On 28 September 2026, the Land Registry and Cadastre General Directorate issued Approval No. 21914825, amending the guideline annexed to Circular 2024/4. The approval followed an approval of the Ministry of Environment, Urbanisation and Climate Change (Çevre, Şehircilik ve İklim Değişikliği Bakanlığı) dated 18 September 2026, No. 21900458, and it changed two rules that every real estate applicant relies on.
The first change concerns time. The interval between the Value Determination Document and the land registry application for a transaction involving citizenship acquisition may now be up to twelve months, instead of six. Where the interval exceeds twelve months, the valuation report underlying the document is renewed. Once the application has been made, the Value Determination Document remains valid until that transaction is completed.
The second change concerns the valuation firm. Between 4 March 2024 and 28 September 2026, only reports prepared by GEDAŞ were accepted for citizenship transactions. From 28 September 2026, the report underlying a Value Determination Document may be prepared by any valuation firm authorised by the Capital Markets Board (Sermaye Piyasası Kurulu), chosen by the applicant or assigned by algorithm through the WebTapu and TADEBİS systems.
The channel did not change. The valuation request is made through WebTapu, using the menu reserved for citizenship transactions, and the Value Determination Document is transmitted electronically to the TAKBİS and WebTapu systems. A Value Determination Document presented on paper at the counter is not processed, and a report ordered for an ordinary transaction cannot later be converted into one for citizenship.
The September changes also restate where responsibility sits. According to published summaries of the new guideline, the Land Registry Directorate’s review of a valuation report is limited to its form, while responsibility for the accuracy of the figure rests with the valuation firm and the staff members who sign the report. Read against the 2026 revocations, the allocation is significant: a false number now has a named author.
Two narrower rules complete the picture. Where a fact affecting the value of the property is registered in the land register after the report is issued, a new report is required even inside the twelve month period. For sales by real estate investment trusts (gayrimenkul yatırım ortaklığı), the trust may submit the valuation it has published on the Public Disclosure Platform (Kamuyu Aydınlatma Platformu) or request a new report; a submitted platform valuation is referred by the Land Registry Directorate to the Department of Foreign Affairs (Yabancı İşler Dairesi Başkanlığı) of the General Directorate.
⚖️ Valuation Rules by Date: Which Period and Which Firm Applied When
The validity period of the valuation used for citizenship has changed three times since 2024, and the permitted valuation firm has changed twice. The table records each version against the dates during which it applied, so that a document can be matched to the rule that governed it on the day it was issued.
| Period | Valuation document | Validity | Permitted valuation firm |
|---|---|---|---|
| Before 4 March 2024 | Valuation report | 3 months | Any firm licensed by the Capital Markets Board |
| 4 March 2024 to 8 December 2024 | Valuation report | 3 months | GEDAŞ only (Circular 2024/2) |
| 9 December 2024 to 27 September 2026 | Value Determination Document (TTB), Circular 2024/4 | 6 months | GEDAŞ only |
| From 28 September 2026 | Value Determination Document (TTB) | 12 months | Any firm authorised by the Capital Markets Board |
The validity periods in the table run from the date of issue of the document to the date of the land registry application. A report issued before 9 December 2024 is governed by the three month rule regardless of when it is presented, and in practice any such report has long since lapsed for citizenship purposes.
The 28 September 2026 approval contains no express transitional provision. On the wording of the amended guideline, the twelve month interval is measured to the date of the land registry application, and published practitioner commentary reads it as covering applications filed on or after 28 September 2026 even where the Value Determination Document was issued earlier. Because the approval itself is silent, a holder of a pre-September document should confirm the position with the Land Registry Directorate before the appointment rather than assume it.
Since the introduction of the Value Determination Document on 9 December 2024, a valuation report is no longer required for transactions with foreign parties that do not involve citizenship acquisition. The valuation requirement and the citizenship purpose now separate at the moment the buyer states the purpose of the acquisition through WebTapu, and that choice determines which menu, which document and which rules apply to the file.
⚖️ How Much Do You Need to Invest? The Threshold History from 2017 to 2026
The real estate threshold has been 400,000 US dollars since 13 June 2022 and did not change in 2026. Two earlier thresholds still govern purchases made before that date, which is why older acquisitions are measured differently from new ones.
| Purchase date | Real estate threshold |
|---|---|
| 12 January 2017 to 18 September 2018 | 1,000,000 USD |
| 19 September 2018 to 12 June 2022 | 250,000 USD |
| From 13 June 2022 | 400,000 USD |
The current 400,000 dollar threshold was introduced by an amendment to the Regulation on the Implementation of the Turkish Citizenship Law published in the Official Gazette on 13 May 2022, No. 31834, with effect from 13 June 2022. The same amendment kept the commitment that the property will not be sold for three years and applied the threshold equally to notarised sales promise contracts.
The threshold is tested against more than the price. Under the guideline annexed to Circular 2024/4, the amount in the foreign currency purchase document, the price declared in the official deed, the value established in the Value Determination Document and the total of the payments made to the seller must each reach 400,000 dollars on its own. A purchase above the threshold that is declared below it in the deed fails on the declared figure.
The 500,000 dollar routes did not change in 2026. A deposit held in Turkish banks for three years, government debt instruments held for three years, units of real estate or venture capital investment funds held for three years and a private pension contribution kept in the system for three years each remain at 500,000 dollars or the equivalent; the fixed capital route also remains at 500,000 dollars, without a fixed holding term in the provision, and the employment route still requires the creation of employment for at least 50 persons. Our separate pages on Turkish citizenship by bank deposit and Turkish citizenship by government bonds set out the mechanics of the two most used alternatives.
⚖️ What Is Turkish Citizenship by Investment? The Seven Routes and Who Certifies Each
Turkish citizenship by investment is an exceptional naturalization route under Article 12, paragraph 1, subparagraph (b) of Law No. 5901 that grants Turkish nationality, by presidential decision, to a foreign investor whose qualifying investment has been verified by a public authority. The minimum is 400,000 US dollars for real estate and 500,000 US dollars for the financial and fixed capital routes, as of 2026.
“Provided that they do not pose an obstacle in terms of national security and public order, the foreigners listed below may acquire Turkish citizenship by decision of the President. […] b) Foreigners who have obtained a residence permit under subparagraph (j) of the first paragraph of Article 31 of the Law on Foreigners and International Protection No. 6458 dated 4/4/2013, Turquoise Card holders, and their foreign spouse and the minor or dependent foreign child of the foreigner and of the spouse.”
Source: Turkish Citizenship Law No. 5901, Art. 12/1-(b) (unofficial translation)
Turkish original: “Millî güvenlik ve kamu düzeni bakımından engel teşkil edecek bir hali bulunmamak şartıyla Cumhurbaşkanı kararı ile aşağıda belirtilen yabancılar Türk vatandaşlığını kazanabilirler. […] b) 4/4/2013 tarihli ve 6458 sayılı Yabancılar ve Uluslararası Koruma Kanununun 31 inci maddesinin birinci fıkrasının (j) bendi uyarınca ikamet izni alanlar ile Turkuaz Kart sahibi yabancılar ve bunların yabancı eşi, kendisinin ve eşinin ergin olmayan veya bağımlı yabancı çocuğu.”
Article 12/1-(b) of Law No. 5901 does not name an investment or an amount. The provision opens the route to holders of a residence permit under Article 31/1-(j) of Law No. 6458, the permit granted on the basis of a qualifying investment, and to Turquoise Card holders; the investment amounts are set one level lower, in Article 20 of the Regulation. The same provision extends the route to the foreign spouse and to the minor or dependent foreign children of the investor and the spouse, which is wider than the “children under 18” found in most guides.
Article 10/1 of Law No. 5901 adds a limit that brochures rarely mention: meeting the conditions does not give the applicant an absolute right to citizenship. The final decision belongs to the President, and under Article 12/2 the Ministry of Interior rejects the applications of persons who pose an obstacle in terms of national security or public order. A certified investment is therefore a condition of eligibility, not a purchase of nationality.
Article 20 of the Regulation on the Implementation of the Turkish Citizenship Law lists seven investment routes in its second paragraph, lettered a to f under the Turkish alphabet, which includes ç. Each route is certified by a different public authority, and the citizenship file moves forward only after that authority issues its eligibility letter. The table shows each threshold as of 2026 and the commitment that follows it.
| Route | Minimum (as of 2026) | Certifying authority | Commitment | Art. 20/2 subparagraph |
|---|---|---|---|---|
| Fixed capital investment | USD 500,000 | Ministry of Industry and Technology | Investment must be realized and verified; no fixed holding term in the provision | a |
| Real estate | USD 400,000 | Ministry of Environment, Urbanisation and Climate Change, through the Land Registry and Cadastre General Directorate | 3-year no-sale annotation on the title deed | b |
| Job creation | 50 employees | Ministry of Labour and Social Security | Continuity of full-time Turkish staff reviewed over the last 6 months | c |
| Bank deposit | USD 500,000 | Banking Regulation and Supervision Agency (BDDK) | Held 3 years as a Turkish lira deposit after conversion | ç |
| Government debt instruments | USD 500,000 | Ministry of Treasury and Finance | Held 3 years in Turkish lira instruments | d |
| Real estate or venture capital fund shares | USD 500,000 | Capital Markets Board (SPK) | Held 3 years, blocked at the Central Securities Depository | e |
| Private pension (BES) | USD 500,000 | Pension funds designated by SEDDK | Kept in the system for 3 years | f |
Two provisions of Article 20 change how the table should be read. Under Article 20/8, an investor can move between investment types to complete the required period, so time already served under one route is not necessarily lost when the investment changes form. Under Article 20/6, monetary values are measured at the Central Bank’s effective selling rate or cross rate on the date of determination, not on the date the investor first planned the purchase.
Most international guides still list six routes and leave out the private pension route added on 13 May 2022. An investor comparing a deposit with government bonds without knowing that a third Turkish lira based financial route exists is comparing an incomplete set. Citizenship through marriage, long-term lawful residence or descent is governed by other provisions and falls outside the scope of this page; those routes are covered in our guide on how to obtain Turkish citizenship.
⚖️ How the Money Must Enter Turkey: the 2022 Currency Rules Still in Force
Since an amendment to the Regulation published on 6 January 2022, the foreign currency used for the real estate, deposit, government bond and investment fund routes, and since 13 May 2022 also for the private pension route, must be sold, before the transaction, to a bank operating in Turkey, which in turn sells it to the Central Bank of the Republic of Türkiye (Türkiye Cumhuriyet Merkez Bankası).
For the deposit route, the Turkish lira obtained from that sale is held in a Turkish lira deposit for at least three years. For the government bond route, the Turkish lira amount is held in Turkish lira denominated government debt instruments for the same period. The investor on either route therefore carries Turkish lira exposure on the invested amount throughout the holding period, a point that comparison tables built on dollar figures tend to omit.
For the real estate route, the conversion is evidenced at the Land Registry Directorate by the foreign currency purchase document (Döviz Alım Belgesi), required for acquisitions by foreign individuals since 24 January 2022. For citizenship files, the bank receipt evidencing the transfer from buyer to seller must be produced alongside it, because conversion alone does not prove that the price reached the seller.
The receipt rules distinguish by date within a single transaction. Receipts for transfers made before the foreign currency purchase document is issued should be denominated in foreign currency; receipts for transfers made after it should be denominated in Turkish lira. For transfers predating 24 January 2022, the receipt is converted into US dollars at the Central Bank’s effective selling rate on the business day preceding the payment date.
None of these currency rules changed in 2026, but the 2026 revocations gave them new weight. A cancellation turns on whether the investment existed as declared, and the currency purchase document and the transfer receipts are the documents that prove it did. An investor who preserves them for the life of the holding period, and beyond, has the evidence that a later review will ask for.
⚖️ Deposit, Bonds, Funds and Pension: How the Financial Routes Are Monitored
The four financial routes each require at least 500,000 US dollars or the equivalent, held for three years, and each is watched by the institution that holds the investment rather than by the investor alone. Banks, the Central Securities Depository and the pension system report on the commitment throughout the three-year period.
“[…] a deposit of at least 500,000 US Dollars or the equivalent amount in foreign currency, on condition that it is held for three years […]”
Source: Regulation on the Implementation of the Turkish Citizenship Law, Art. 20/2-(ç) (unofficial translation)
Turkish original: “En az 500.000 Amerikan Doları veya karşılığı döviz tutarında mevduatı üç yıl tutma şartıyla […]”
Article 20/2-(ç) of the Regulation makes the Banking Regulation and Supervision Agency (Bankacılık Düzenleme ve Denetleme Kurumu) the certifying authority for the deposit route. Read together with Article 20/10, the deposit is held in Turkish lira after conversion, so the exchange rate works on the investment for the full three years, and the Regulation itself contains no currency protection for that balance.
Government Debt Instruments
The government bond route is certified by the Ministry of Treasury and Finance and requires at least 500,000 US dollars of Turkish lira government domestic debt securities or specified lira lease certificates, held for three years. Instruments with less than three years left to maturity are not used. The instrument must be bought on the day of the currency sale or the next business day at the same bank, with no transfer between banks.
The Ministry of Treasury and Finance procedures require the bank to send the file by registered electronic mail (KEP) or registered post; files sent only by ordinary e-mail are not considered. Deficient files receive 20 business days for correction, and banks report on the three-year commitment once a month. The procedure is published in the Ministry’s procedures for exceptional citizenship through government debt instruments.
Real Estate and Venture Capital Fund Shares
The fund route is certified by the Capital Markets Board (Sermaye Piyasası Kurulu) and requires at least 500,000 US dollars of participation shares in a real estate investment fund or a venture capital investment fund, held for at least three years. The shares are blocked in a citizenship sub-account at the Central Securities Depository (Merkezi Kayıt Kuruluşu, MKK) at the investor’s request, and the MKK checks the accounts weekly.
The Capital Markets Board procedure runs on a short official timetable: the Board writes to the MKK within 2 business days of a complete file, the MKK replies within 3 business days, and the certificate is issued within 2 business days after that. A pledge, attachment or injunction on the shares means the three-year condition is treated as unmet, according to the Board’s guidance for foreign investors.
Private Pension (BES)
The private pension route, added to Article 20/2-(f) on 13 May 2022, requires a contribution of at least 500,000 US dollars or the equivalent into the Individual Pension System (Bireysel Emeklilik Sistemi), held in funds designated by the Insurance and Private Pension Regulation and Supervision Agency (SEDDK) and kept in the system for three years. The contribution is converted to Turkish lira under Article 20/10 before it enters the fund. The process is set out on our page on Turkish citizenship with a BES plan.
⚖️ Fixed Capital and Job Creation: The Business Routes
The two business routes are the fixed capital route, which requires at least 500,000 US dollars of fixed capital investment certified by the Ministry of Industry and Technology, and the job creation route, which requires at least 50 jobs certified by the Ministry of Labour and Social Security. Neither provision sets a fixed three-year holding term in the way the financial routes do; both are tested on substance.
“[…] has made a fixed capital investment of at least 500,000 US Dollars or the equivalent amount in foreign currency […]”
Source: Regulation on the Implementation of the Turkish Citizenship Law, Art. 20/2-(a) (unofficial translation)
Turkish original: “En az 500.000 Amerikan Doları veya karşılığı döviz tutarında sabit sermaye yatırımı gerçekleştirdiği […]”
Article 20/2-(a) of the Regulation uses the past tense: the fixed capital investment must already be realized, not planned. The Ministry of Industry and Technology looks for capital reflected in company records, financial statements and, where the sector requires it, licenses. A capitalized company with no operational substance is the profile most likely to be questioned. Thresholds and review practice are explained on our page on Turkish citizenship by fixed capital investment.
The job creation route requires a total of at least 50 Turkish citizens employed in the company or companies the applicant owns or is a partner in. The Ministry of Labour and Social Security assesses whether the ownership share is sufficient and looks at the continuity of full-time Turkish employees over the last six months. Social security records support the file, but the Ministry, not the social security institution, makes the determination. The Ministry of Labour and Social Security (Çalışma ve Sosyal Güvenlik Bakanlığı) was created on 21 April 2021, when the former Ministry of Family, Labour and Social Services was split in two, so older guides that name the earlier ministry describe the same certifying role.
Complete job creation applications are concluded within seven business days under the Ministry’s published procedure, and missing documents receive a 30-day completion period, after which the application is rejected. The Ministry’s document list is published on its exceptional citizenship information page, and payroll evidence is covered on our page on Turkish citizenship by job creation.
⚖️ Which Properties Still Qualify After December 2023?
Since an amendment to Article 20 of the Regulation published in the Official Gazette on 12 December 2023, a property acquired for citizenship must be registered as an independent unit with condominium ownership or construction servitude established under Condominium Law No. 634 (Kat Mülkiyeti Kanunu), or, where it is registered with land classification, carry a permanent building with an occupancy permit.
“[…] has purchased real property worth at least 400,000 US Dollars or the equivalent amount in foreign currency on which condominium ownership or construction servitude has been established, or a property classified as a plot with a building on it, on condition that a three-year no-sale annotation is placed in the title deed records […]”
Source: Regulation on the Implementation of the Turkish Citizenship Law, Art. 20/2-(b) (unofficial translation)
Turkish original: “En az 400.000 Amerikan Doları veya karşılığı döviz tutarındaki kat mülkiyeti veya kat irtifakı kurulmuş ya da üzerinde yapı bulunan arsa vasıflı taşınmazı tapu kayıtlarına üç yıl satılmaması şerhi koyulmak şartıyla satın aldığı […]”
Article 20/2-(b) of the Regulation names the Ministry of Environment, Urbanisation and Climate Change, acting through the land registry, as the authority that certifies the real estate investment. The same subparagraph accepts a notarised promise-to-sale contract instead of a completed purchase only where the property already has condominium ownership or construction servitude, the full 400,000 dollars is paid in advance and a three-year non-transfer commitment is annotated in the land register.
The 12 December 2023 amendment closed the bare land route. Before that date, a plot of land without a building could support an application if it reached the threshold; after it, a plot without a lawful building does not qualify at any price. Several international guides still list land as an eligible asset class almost three years after the change, which makes the amendment one of the most frequently misreported rules of the program.
Further exclusions in the current guideline operate independently of value. A property acquired in fractional shares cannot support an application, timeshare rights are excluded, and a property may be used for citizenship acquisition only once, even after its owner changes and the earlier holding period has expired. A single history check in the land register answers all three questions before a deposit is paid.
The guideline also restricts who may sell. A property transferred after 12 January 2017 by the buyer, the buyer’s spouse or children, or by a foreign individual of the same nationality as the buyer, to a Turkish citizen or company cannot be bought back for the purpose; nor can property registered to a company in which the buyer’s family holds shares or a directorship, or to the buyer’s first-degree Turkish relatives. The complete list, with the conditions for second-hand properties, is set out in our guide to buying property in Turkey for citizenship.
⚖️ What Did Not Change in 2026
The legal foundation of the program, its thresholds and its family scope were untouched in 2026. Citizenship by investment is still granted by presidential decision under Article 12, paragraph 1, subparagraph (b) of Law No. 5901, on the basis of an investment conformity certificate issued by the authority competent for the route chosen.
The three year commitment did not change. For the real estate route, an undertaking that the property will not be sold for three years is annotated in the land register at registration, and the period runs from the date of registration rather than from the date of approval. Renting the property, living in it and receiving income from it remain permitted throughout the three year period.
The family scope of an application did not change. Under Article 12/1-(b) of Law No. 5901, the principal applicant may include the foreign spouse and the minor or dependent foreign children of the applicant and the spouse in the same file, and the principal applicant and the spouse attend once for biometric registration, either at a provincial directorate of the Presidency of Migration Management (Göç İdaresi Başkanlığı) or at a Turkish consulate abroad. How family members are added is set out in our note on Turkish citizenship for spouse and children.
The residence link did not change either. Article 12/1-(b) of Law No. 5901 opens the investment route to holders of a residence permit under Article 31, paragraph 1, subparagraph (j) of the Law on Foreigners and International Protection No. 6458 (Yabancılar ve Uluslararası Koruma Kanunu) and to Turquoise Card holders. The permit is a separate procedure with its own documents and does not replace the citizenship application, but it is the status the citizenship provision refers to.
Tax reforms adopted in 2026 for foreign investors and new residents do not change citizenship eligibility, and this page does not cover them. Their effect is on the investor’s position after acquiring nationality and becoming resident, and they are analysed on our pages covering the 2026 Turkey tax update for foreign investors and the twenty year tax exemption for new residents.
⚖️ Does Citizenship Wait for the Three Years to End?
Turkish citizenship by investment does not require the investor to wait three years before applying. The three-year period is a holding commitment that starts when the qualifying amount is registered, annotated or blocked, and it runs in parallel with the citizenship process. The citizenship file moves forward once the certifying authority issues its eligibility letter.
The sequence, in the order the authorities see it:
- Structuring and source-of-funds documentation, before any currency is converted.
- Sale of the foreign currency to a bank in Turkey and completion of the investment.
- Eligibility letter or investment conformity certificate from the certifying authority.
- Residence permit under Article 31/1-(j) of Law No. 6458 based on the same investment, the status Article 12/1-(b) of Law No. 5901 refers to.
- Citizenship application file and a single biometric appointment for the main applicant and spouse.
- Security and file review, followed by a presidential decision.
- Continued monitoring of the three-year commitment by the bank, registry or depository.
The start date of the three-year period differs by route. For real estate it is the annotated title registration. For government bonds, the Ministry of Treasury and Finance procedure counts from the blocking date on which the minimum amount was met. For fund shares, the Capital Markets Board procedure counts from the date the minimum amount was reached, and the period must be uninterrupted. Payment alone, without registration, does not start the period.
Neither Law No. 5901 nor the Regulation sets a deadline for the presidential decision, which is why published estimates of the total duration differ from one guide to the next. What the Regulation does fix is the life of the security check: under Article 72/4, the investigation and archive research on an applicant remain valid for one year and may be repeated earlier where necessary, and Article 35/2 requires archive research by the National Intelligence Organisation and the General Directorate of Security for every Article 12 file.
Fixed official deadlines exist only for the certifying steps. Complete job creation files are concluded within seven business days under the Ministry of Labour and Social Security procedure, and the Capital Markets Board and MKK chain for fund shares runs on 2, 3 and 2 business days. Any total duration quoted for the citizenship decision itself is an estimate from practice, not a statutory period, and should be read as one.
⚖️ What Happens If You Sell, Withdraw or Switch Before Three Years?
Selling, withdrawing or reducing a qualifying investment by the investor’s own choice before three years have passed breaks the condition the eligibility letter was issued on. The holding institutions watch for it: banks report government bond commitments to the Ministry of Treasury and Finance monthly, and the MKK checks fund accounts weekly and informs the Capital Markets Board within 3 business days of any reduction.
When the Capital Markets Board learns that a fund position has been unblocked, reduced or encumbered, it notifies the Presidency of Migration Management, the General Directorate of Population and Citizenship Affairs and the applicant. A broken commitment can therefore surface after citizenship has been granted, not only during the application, which is the same review mechanism behind the 2026 revocations described above.
A decline caused by the market is treated differently from a reduction caused by the investor. The Ministry of Treasury and Finance and Capital Markets Board procedures both state that a fall below 500,000 dollars caused by market or exchange rate movements does not affect the application. Fund distributions made under the fund’s own rules, such as dividends or liquidation payments, also do not count as an investor reduction.
Switching routes is permitted under Article 20/8 of the Regulation, which allows an investor to move between investment types to complete the required period. An investor two years into a bond position can, in principle, move into another qualifying route rather than lose the time already served, provided the new investment meets its own conditions on the day it starts and the transition is planned before any instruction is given to the bank.
⚖️ Common Mistakes That Cost Investors the Application
Eight mistakes account for most of the citizenship-by-investment files we are asked to repair, and almost all of them are made before the investment, not during review:
- Planning a US dollar or euro deposit, when the deposit route has required conversion to Turkish lira since 2022.
- Buying bare land, a timeshare or a fractional share after 12 December 2023.
- Buying from a seller the guideline excludes, such as a first-degree relative or a family company.
- Declaring a price below 400,000 dollars in the deed while paying more.
- Ordering the valuation through the ordinary WebTapu menu instead of the citizenship menu.
- Choosing a government bond with less than three years to maturity.
- Pledging fund shares or the property as loan security during the holding period.
- Comparing only six routes and never looking at the private pension option.
Outdated information is behind most of these mistakes. The Regulation changed the real estate threshold in 2018 and 2022, added the currency conversion rule and the pension route in 2022 and narrowed eligible property types in 2023, and the valuation regime changed again in 2024 and 2026. Guidance written before September 2026 can still describe a six month valuation period or a single permitted valuation firm.
⚖️ Can I Keep My Passport? Dual Citizenship, Other Costs and What the Turkish Passport Gives You
Yes, an investor does not have to give up an existing nationality to acquire Turkish citizenship by investment. Article 20 of the Regulation contains no renunciation condition for the investment route, unlike Article 15/2, which allows renunciation to be required in the general naturalization route, and Law No. 5901 defines and records multiple citizenship.
“Multiple citizenship: a Turkish citizen holding more than one citizenship at the same time”
Source: Turkish Citizenship Law No. 5901, Art. 3/1-(b) (unofficial translation)
Turkish original: “Çok vatandaşlık: Türk vatandaşının aynı anda birden çok vatandaşlığa sahip olmasını”
Article 3/1-(b) of Law No. 5901 treats multiple citizenship as a recognised status, and Article 44 provides for it to be noted in the civil registry once the person’s identity in both systems is confirmed. Whether the investor’s home country also allows a second nationality is a question of that country’s own law, and some countries withdraw their nationality automatically when another is acquired.
The threshold is not the total cost. The 400,000 and 500,000 dollar figures measure the investment only: for real estate, the foreign currency purchase document, the declared deed price, the Value Determination Document and the payments to the seller must each reach the threshold on their own, and none of the transaction costs below is added to them. Rates change, so the cost of a file is calculated on the date of the transaction rather than taken from a published summary.
| Cost item | Official basis | Counts toward the threshold? | How the amount is set |
|---|---|---|---|
| Title deed fee | Statutory fee charged at the land registry on transfer | No | Rate set by law, applied to the declared price |
| Municipal market value document | Land registry requirement for foreign buyers | No | Issued by the municipality where the property is located |
| Compulsory earthquake insurance (DASK) | Land registry requirement for buildings | No | Premium depends on the building |
| Valuation report and Value Determination Document | Land Registry and Cadastre circular 2024/4 and the 28 September 2026 approval | No | Fee charged by the valuation firm |
| Sworn interpreter, notarised translations, apostilles | Land registry and citizenship file requirements | No | Market rates of interpreters and notaries |
| Value added tax, where it applies | Tax law on the sale of the property | No | Depends on the property and the seller |
| Citizenship service fee | Law No. 5901, Article 45 | No | Set jointly by the Ministry of Interior and the Ministry of Treasury and Finance |
| Legal and agency fees | Contract between the investor and the adviser | No | Agreed in the engagement or brokerage contract |
The land registry requirements in the table follow the official checklist published by the Investment Office of the Presidency, Invest in Türkiye, which also confirms that the buyer states the citizenship purpose in the land registry application, declares that the property will not be sold for three years, and then applies for residence or citizenship with the certificate of eligibility issued for the owner.
A Turkish passport also opens the United States E-2 treaty investor visa, because Turkey has been an E-2 treaty country since 18 May 1990 according to the US Department of State treaty country list. The route and its conditions are explained on our page on the E-2 visa through Turkish citizenship. Visa-free access to other destinations changes with bilateral arrangements, and the Schengen position is covered on our page on Turkish citizenship and the Schengen visa.
⚖️ Does an Application Already in Progress Need to Change Anything?
An application in progress needs to change only the steps that have not yet happened. A purchase already registered is measured against the threshold that applied on its registration date, and nothing published under the Turkish citizenship by investment 2026 rules reopens that measurement.
An investor holding a Value Determination Document issued before 28 September 2026, with the land registry application still ahead, is the person most directly affected. If the document is older than six months, the twelve month rule may keep it usable; if it is older than twelve months, a new report is required in any case. The position should be confirmed with the Land Registry Directorate before an appointment is booked, given the absence of an express transitional provision.
An investor who had planned to order a new valuation now has a choice of firm that did not exist between March 2024 and September 2026. Any firm authorised by the Capital Markets Board may now prepare the report, through the citizenship menu of WebTapu. Choosing a firm is a decision about the reliability of a number that will be read again if the file is ever reviewed, not merely a decision about fees.
An investor whose citizenship has already been granted needs to change nothing procedurally, but should check one practical point: whether the full set of investment records survives in usable form. The valuation report, the declared price, the transfer receipts and the foreign currency purchase document are the evidence that answers a review. Files approved before the 2024 valuation reforms deserve that check first.
⚖️ The Price Stayed Still; the Proof Did Not
Four years after the threshold last moved, the program looks unchanged to anyone who reads only its prices. It has changed for anyone who reads its procedures. Valuation has passed from open market to single firm and back to an open market with sharper responsibility; the life of the valuation document has gone from three months to six to twelve; and the authorities have shown that a file approved years ago can still be reopened.
The common thread is proof. Each change since 2022 concerns how the state satisfies itself that the investment declared is the investment made. An investor who builds the file around that question, with a reliable valuation, a declared price that matches it and a payment trail that survives the holding period, is applying under the rules that will matter in 2026 and in the years of review that follow.
Schedule a Legal Consultation
Whether you are starting a file under the September 2026 valuation rules, holding a valuation issued before the change, or reviewing an approved file in light of the 2026 revocations, our Citizenship and Investment Lawyers in İstanbul are available for an initial consultation.